OCC Risk Disclosure Statement and Acknowledgements

OCC Risk Disclosure

I acknowledge that:

1. I have received and carefully read each section of, and the supplements to, the Options Clearing Corporation ("OCC") document "Characteristics and Risks of Standardized Options" (the "OCC Risk Disclosure Document") ;
   
   
2. I have received and carefully read the "Special Statement for Uncovered Option Writers" (set forth below);
   
   
3. I have received and carefully read the "Disclosure Regarding Interactive Brokers' Procedures for Allocating Equity Option Exercise Notices Assigned by OCC" ("IB Exercise Allocation Disclosure"); (Requires Adobe Reader. Download Reader.)
   
   
4. I understand the OCC Risk Disclosure Document, the "Special Statement for Uncovered Option Writers" and the IB Exercise Allocation Disclosure, each of which is in a language I fully understand; and
   
   
5. If there is any aspect of the OCC Risk Disclosure Document, the "Special Statement for Uncovered Option Writers" or the IB Exercise Allocation Disclosure that I do not understand, I shall consult my independent adviser and obtain a full understanding of such term(s).

Special Statement for Uncovered Option Writers

There are special risks associated with uncovered option writing which expose the investor to potentially significant loss. Therefore, this type of strategy may not be suitable for all customers approved for options transactions.

1. The potential loss of uncovered call writing is unlimited. The writer of an uncovered call is in an extremely risky position, and may incur large losses if the value of the underlying instrument increases above the exercise price.
   
   
2. As with writing uncovered calls, the risk of writing uncovered put options is substantial. The writer of an uncovered put option bears a risk of loss if the value of the underlying instrument declines below the exercise price. Such loss could be substantial if there is a significant decline in the value of the underlying instrument.
   
   
3. Uncovered option writing is thus suitable only for the knowledgeable investor who understands the risks, has the financial capacity and willingness to incur potentially substantial losses, and has sufficient liquid assets to meet applicable margin requirements. In this regard, if the value of the underlying instrument moves against an uncovered writer's options position, the investor's broker may request significant additional margin payments. If an investor does not make such margin payments, the broker may liquidate stock or options positions in the investor's account, with little or no prior notice in accordance with the investor's margin agreement.
   
   
4. For combination writing, where the investor writes both a put and a call on the same underlying instrument, the potential risk is unlimited.
   
   
5. If a secondary market in options were to become unavailable, investors could not engage in closing transactions, and an option writer would remain obligated until expiration or assignment.
   
   
6. The writer of an American-style option is subject to being assigned an exercise at any time after he has written the option until the option expires. By contrast, the writer of a European-style option is subject to exercise assignment only during the exercise period.

NOTE: It is expected that you will read the booklet entitled CHARACTERISTICS AND RISKS OF STANDARDIZED OPTIONS available from your broker. In particular your attention is directed to the chapter entitled Risks of Buying and Writing Options. This statement is not intended to enumerate all of the risks entailed in writing uncovered options.

Risks of Trading Equity Options and Terms and Conditions for Trading Equity Options

Customers trading equity options understand and agree to the following:

1. Customer understands that trading equity options is highly speculative in nature and involves a high degree of risk.
   
   
2. Customer acknowledges that Customer has read and fully understands (a) the current Options Clearing Corporation ("OCC") disclosure document "Characteristics and Risks of Standardized Options" (the "OCC Document") and (b) the "Special Statement for Uncovered Option Writers." Customer agrees to seek clarification of any term, condition or risk contained in either of these documents prior to making such acknowledgment to IB.
   
   
3. Customer is financially able to undertake the risks associated with trading equity options and withstand any losses incurred in connection with such trading (including the total loss of premiums paid by Customer for long put and call options, margin requirements for short put and call options, and transaction costs).
   
   
4. Among the risks Customer acknowledges are: (a) option contracts are traded for a specified period of time and have no value after expiration; (b) trading halts in the underlying security, or other trading conditions (for example, volatility, liquidity, systems failures) may cause the trading market for an option (or all options) to be unavailable, in which case, the holder or writer of an option would not be able to engage in a closing transaction and an option writer would remain obligated until expiration or assignment.
   
   
5. The IB System is an electronic system and is, therefore, subject to unavailability. Customer represents that it has alternate trading arrangements for the placement of Customer's orders and shall use such arrangements in the event that the IB System becomes unavailable. Although the IB System is designed to perform certain automatic functions, IB does not warrant that the IB System will perform as it is designed to, and IB will not have any liability to Customer for losses or damages which result from such failures of performance or unavailability. Subject to the foregoing, Customer acknowledges that the IB System is designed to automatically liquidate Customer positions if Customer's account equity is not sufficient to meet margin requirements.
   
   
6. Customer has reviewed and understands the applicable margin requirements for trading equity options.
   
   
7. Each equity option transaction entered into is subject to the rules and regulations of the Securities & Exchange Commission ("SEC"), the Financial Industry Regulatory Authority ("FINRA"), the OCC, the self-regulatory organizations that regulate IB and, the relevant options exchanges. Customer is aware of and agrees to be bound by the rules applicable to the trading of options contracts promulgated by the SEC, FINRA, the OCC and the self-regulatory organizations that regulate IB and the relevant options exchanges.
   
   
8. Equity options traded in the US are issued by the OCC.
   
   
9. Customer is aware of and agrees not to, alone or in concert with others, exceed the position and exercise limits imposed by FINRA or by other exchange rules and regulations, including but not limited to FINRA Rules 2360(b)(3) and (4).
   
   
10. With certain exceptions, IB will not execute a Customer order to purchase an equity option if Customer does not have equity in its account at least equal to the full purchase price of a put or call option (equity options may not be purchased on margin).
    
    
11. Customer shall comply with IB margin requirements in connection with Customer's sale of put and call options.
    
    
12. Customers who wish to exercise an option on a particular trading day acknowledge that they must provide specific, written instructions to IB using the procedure specified on the IB website before the Close Out Deadline specified. Customer further acknowledges that, absent receipt of such instructions, IB has no obligation to exercise Customer's option on any given trading day or prior to the expiration of the option. Customer acknowledges that, subject to paragraph H below, OCC will automatically exercise any long equity option held by a Customer that is in-the-money by $.01 or more at expiration, absent specific instructions to the contrary provided by Customer to IB using the procedures specified on the IB website.
    
    
13. Customer understands that OCC assigns exercises to clearing firms such as IB and Customer acknowledges that it has read and understands the description of the OCC assignment procedures available on request from the OCC as set forth in Chapter VIII of the OCC Document. Customer acknowledges that, upon assignment, Customer shall be required: (1) in the case of an equity option, to deliver or accept the required number of shares of the underlying security, or (2) in the case of an equity index option, to pay or receive the settlement price, in cash. Customer understands that it may not receive notice of an assignment from IB until one or more days following the date of the initial assignment by OCC to IB and that the lack of such notice creates a special risk for uncovered writers of physical delivery call stock options. Customer acknowledges that it has read and understands this risk as described in Chapters VIII and X of the OCC Document.
    
    
14. Customer is responsible for entering an offsetting transaction to close out a Customer position, or to exercise an equity option by written e-mail instruction to IB prior to the expiration date, and Customer's failure to do so may result in the equity option expiring worthless, regardless of the monetary value of the equity option on its expiration date.
    
    
15. If, prior to expiration of an option contract, Customer does not have sufficient equity to meet the initial margin requirement for the purchase or sale of the underlying security (the higher of IB's "house" margin requirements or margin requirements mandated by exchanges or regulators), then IB shall have the option, at its discretion, to: (1) decline to purchase or sell such underlying security for the customer's behalf (e.g., by filing a Contrary Exercise Notice): OR (2) exercise the option and liquidate the underlying security position which results from the exercise of the option contract. If Customer violates the IB Customer Agreement by failing to close out an open option position prior to expiration, which creates a margin deficiency (e.g., upon exercise or automatic exercise of the option), then Customer shall be liable for resulting losses and costs and shall not be entitled to any profits or gains.
    
    
16. In connection with the exercise of a long put option that results in a short position in the underlying stock, Customer acknowledges that: (1) short sales may only be effected in a margin account and are subject to initial and maintenance margin requirements; and (2) if IB is unable to borrow such stock on Customer's behalf or if a lender subsequently issues a recall notice for such stock, then IB, without notice to Customer, is authorized by Customer to cover Customer's short position by purchasing stock on the open market at the then current market price and Customer agrees that it shall be liable for any resulting losses and all associated costs incurred by IB. As noted above, the market value of short stock is treated as a debit item to Customer's IB margin account.

Stock Stop Order Disclosure

Interactive Brokers ("IBKR") is furnishing this document to you to provide information about the manner in which stop and stop-limit orders that you submit to IBKR to buy or sell stocks and warrants will be managed.

A stop order is an order to buy or sell a stock once the price of the stock reaches a specified price, known as the stop price. When the stop price is reached, a stop order becomes a market order. A buy stop order is entered at a stop price above the current market price. A sell stop order is entered at a stop price below the current market price. Investors generally use a sell stop order to limit a loss or to protect a profit on a stock that they own.

A stop-limit order is an order to buy or sell a stock that combines the features of a stop order and a limit order. Once the stop price is reached, a stop-limit order becomes a limit order that will be executed at a specified price (or better).

IBKR offers its customers several ways to submit stop and stop-limit orders in stocks and warrants. On most exchanges, IBKR implements and manages stop (or stop-limit) orders in the firm's systems, submitting market (or limit) orders to the exchange when the customer-specified trigger price has been reached and passed. On some exchanges, IBKR may submit stop and/or stop- limit orders using the exchange's native order type. For each exchange on which a customer may trade, IBKR specifies on the IBKR website whether stop and stop-limit orders are managed (i.e., "simulated") by IBKR or submitted using the exchange's native order type. (This information is available under "Order Type" on the page on the IBKR website concerning each exchange.)

For stop and stop-limit orders that IBKR simulates, the order will be triggered and a market (or limit) order will be submitted for execution when the following occurs (unless the customer specifies otherwise when submitting the order):

1. The primary exchange on which the stock trades is open, is holding regular trading hours, and has a valid bid/ask quote for the stock. Regular trading hours are usually between 9:30a.m. - 4:00p.m. Eastern Time, Monday through Friday for U.S. exchange-listed stocks. (Please note that OTCBB- and Pink- listed securities are not subject to these limitations.); and
   
   
2. The last sale price for the specific stock is at or above (for buy stop orders) or at or below (for sell stop orders) the customer's specified trigger price; and
   
   
3. The last trade price is within, or not more than 0.5% outside of, the consolidated bid/ask for the stock.

These additional requirements are subject to change, including the leeway percentage of 0.5% outside of the consolidated bid/ask for the stock. Please check the IBKR website for the most current information.

IBKR also allows customers to customize the manner in which their stop and stop-limit orders are triggered. Customers may change the trigger method to include or exclude certain trigger criteria (e.g., last price, bid/ask, midpoint of bid/ask, regular trading hours only, etc.) based on the customer's specific trading objectives. Information on how to customize the trigger methodology for stop and stop-limit orders is provided on the IBKR website and in the IB Trader Workstation User's Guide.

Important notes concerning stop and stop-limit orders:

1. Native Stop or Stop-Limit Order Types Offered by Exchanges May Differ from the Traditional Order Type. Stop and stop-limit orders submitted using an exchange's native order type may have additional non-standard attributes or be managed in a way different than the traditional definition of a stop or stop-limit order. Please review the exchange's own website and/or contact the exchange for more information about how an exchange may handle a stop or stop-limit order submitted using the exchange's native order type. Among other things, exchanges may include attributes in native stop orders that result in the order not executing at all.
   
   
2. There is No Guarantee That a Stop or Stop-Limit Order Will Be Executed At or Near the Trigger Price or Will Be Executed At All. Please be aware that a stop or stop-limit order may not be triggered or be executed at or near the specified trigger price. Among other things, execution venues may fail to honor their posted prices or may experience delays or failures that may prevent or delay a stop order from being executed. In addition, market events may result in a stop order executing far from the customer's specified trigger price. For instance, in situations where many customers submit a stop order with a similar trigger point or there is a lack of liquidity in the market, a stop order may execute a significant amount away from the specified trigger price and a stop-limit order may not execute at all.

Notice Regarding Pre-Arranged Trading On U.S. Futures Exchanges

Pre-arranged trading results when a discussion is held by market participants prior to trade execution to ensure that a contra party will take the opposite side of a particular order. U.S. futures exchanges, including, but not limited to, CME, CBOT, NYMEX, ICE-US, CFE and Small Exchange, Inc. have regulations regarding the execution of pre-arranged trades. Interactive Brokers customers are responsible to know and abide by ALL exchange restrictions regarding pre-arranged trading. Interactive Brokers customers should not engage in pre-arranged trading unless such transactions are permitted by the relevant exchange. Customers should review the rules of each exchange to determine whether, and under what circumstances, such transactions are permitted. For your reference, various exchange rulebooks can be found at the following websites:

CME, CBOT, NYMEX
http://www.cmegroup.com/market-regulation/rulebook/

ICE Futures U.S.
https://www.theice.com/futures-us/regulation#Rulebookf

CFE
https://www.cboe.com/us/futures/regulation/

Small Exchange, Inc.
https://www.thesmallexchange.com/regulation-page

Required Disclosures and Supplemental Agreement for Security Futures Trading at Interactive Brokers

1. Introduction
   This information is being provided to you by Interactive Brokers ("IB") to ensure that you understand the risks inherent in trading security futures and also so that you understand how your security futures account is being handled by IB. You must review this document carefully and sign it at the bottom in order to be approved to trade security futures products through IB.

   You should be aware that security futures are highly leveraged investments and the risk of loss in trading these products can be substantial. Security futures are not suitable for all investors and you must carefully review this document and consult with a financial advisor, if necessary, to determine whether to trade security futures. IB does not provide any investment advice or recommendations, and you will be solely responsible for decisions regarding the security futures trading conducted in your account.

2. Nature of Your Security Futures Account
   Under the federal regulations that apply to security futures, security futures positions may be held in a securities trading account subject to Securities and Exchange Commission (SEC) regulations or in a commodities trading account subject to Commodity Futures Trading Commission (CFTC) regulations.

   Because IB is fully registered with both the SEC and the CFTC, IB offers both securities accounts and commodities accounts. Most securities futures products are held in an IB securities account and are subject to SEC customer protection rules. However, certain securities futures products are held in a commodities account and are therefore subject to CFTC customer protection rules. Additional information regarding whether a particular securities future product is held in a securities or commodities account may be found on IB's website.

   The types of protections offered to investors for securities and commodities accounts are different. The different protections available to securities accounts and commodities accounts are described in Section 6 of the FINRA/NFA Standardized Risk Disclosure for Security Futures Contracts, discussed below.

3. Standardized Risk Disclosure for Security Futures Contracts
   The National Futures Association (NFA) and the Financial Industry Regulatory Authority (FINRA) have jointly prepared a Standardized Risk Disclosure for Security Futures Contracts. It contains valuable information regarding trading of security futures contracts and you should review it carefully before investing in security futures.

   To review the FINRA/NFA Standardized Risk Disclosure for Security Futures Contracts, click here.

   NOTE: Viewing the Standardized Risk Disclosure requires Adobe Acrobat. To download Adobe Acrobat, click here. If you wish to receive a hard copy of the disclosure, call IB Customer Service at (877) 442-2757.

4. Supplemental Agreement for Security Futures Trading
   The Supplemental Agreement provisions below relate to security futures trading in Customer' s IB account and are in addition to the terms and conditions of the IB Customer Agreement, and the Customer Agreement is incorporated herein by reference.

   By signing below, Customer acknowledges and agrees to the following:

1. Customer acknowledges that Customer's U.S. and non-U.S. securities futures positions may be held in either a securities or commodities account, in IB's sole discretion. Customer acknowledges that U.S. and non-U.S. listed securities futures held in an IB securities account will receive the regulatory protections of a securities account. Customer acknowledges that U.S. and non-U.S. listed securities futures held in an IB commodities account will receive the regulatory protections of a commodities account.
2. Customer acknowledges that IB may in the future, at its sole discretion, decide to hold customer security futures positions in IB securities accounts or commodities accounts and may not allow customers to make this choice. If IB determines to do this, it will provide required notice to customers of the change.
3. Customer represents that Customer has received and reviewed the FINRA/NFA Standardized Risk Disclosure for Security Futures Contracts.
4. Customer acknowledges that security futures are highly leveraged investments that are not suitable for all investors. Customer acknowledges that IB representatives are not authorized to provide investment, trading or tax advice and therefore will not provide advice or guidance on trading or hedging strategies involving security futures. Customers who need advice or guidance regarding security futures trading or investments should consult a financial advisor.
5. Customer acknowledges that Customer must review and be aware of, and that Customer is bound by, the rules applicable to the trading of security futures, as established by FINRA, the NFA and the security futures exchanges. Customer represents that it is aware of and agrees not to violate any applicable position limits regarding security futures.

Interactive Brokers LLC General Disclosure on Mutual Funds

Important Information Regarding Mutual Funds

1. Interactive Brokers offers customers the ability to invest in certain mutual funds. By making a mutual fund or mutual fund family available to customers, IB does not guarantee the appropriateness or suitability of any mutual fund investment nor do we make any recommendation of any kind.
   
   
2. A mutual fund’s past performance is no indication of future results. A mutual fund’s performance can change over time depending upon a variety of market conditions and share prices can fluctuate on a daily basis. Your investment may be worth more or less than your original cost when you redeem your shares.
   
   
3. IB recommends that customers carefully read the fund’s prospectus prior to investing in the shares of a mutual fund. The prospectus contains important information about the fund’s objectives, investment strategies, risks and expenses. Customers may obtain a copy of a fund’s prospectus by contacting the fund or visiting the fund’s website. Customers may also contact IB Customer Service at (877) 442-2757 to request a prospectus. Please note, IB cannot verify or otherwise guarantee the accuracy or completeness of any mutual fund prospectus, statement of additional information, report to shareholders or proxy solicitation materials.
   
   
4. Certain mutual funds made available through IB invest in international securities. Internationally invested mutual funds can carry certain risks, including, but not limited to, political and economic instability, fluctuations in currency exchange rates, foreign taxes, and differences in regulatory requirements and financial accounting standards. Prior to making an investment decision, customers are encouraged to carefully read the prospectus of any mutual fund that invests internationally.
   
   
5. Some funds may require a minimum holding period for their shares. Some funds charge an early redemption fee if they are sold before a stated holding period ends. Please refer to the fund’s prospectus to see if these conditions apply.
   
   
6. As a mutual fund shareholder, you may receive taxable dividends and/or capital gains on your mutual fund investment. IB does not provide tax advice. Mutual fund investors should consult with their tax advisor in order to determine the impact of taxes on their mutual fund investment.
   
   
7. In addition to Interactive Broker's transaction fee for mutual fund transactions, some mutual funds impose marketing and shareholder servicing fees (e.g., 12b-1 fees). Interactive Brokers may receive a portion of these fees as compensation for shareholder and marketing services rendered. For information regarding a particular mutual fund's payment and compensation practices, please read the fund's prospectus and statement of additional information or visit the fund's website. IB may share a portion of the compensation received from fund companies with your financial advisor.
   
   
8. Mutual Fund Order Deadline. Please note that all mutual fund orders received prior to the close of the New York Stock Exchange (generally, 4:00 p.m. EST) will receive the mutual fund’s NAV price for that day provided the order is received on a trading day. Any mutual fund orders received after the close of the New York Stock Exchange will receive the following trading day’s NAV share price. Any mutual fund orders received on days when the New York Stock Exchange is closed (e.g., holidays) will receive the following trading day’s NAV share price.

Interactive Brokers Municipal Securities Disclosure

Interactive Brokers LLC

Interactive Brokers LLC is registered with the U.S. Securities and Exchange Commission and the Municipal Securities Rulemaking Board ("MSRB").We encourage you to review the information available from The Financial Industry Regulatory Authority (FINRA) at www.finra.org and the MSRB at www.msrb.org regarding the trading of municipal securities. We have included links to specific documents available on these websites that you should review and be familiar with before trading municipal securities.

FINRA Investor Alert: Municipal Bonds - Important Considerations for Individual Investors

MSRB Brochure: Information for Municipal Securities Investors

Disclosure Regarding Trading of Certificates of Deposit

Trading Certificates of Deposit ("CDs"), even those that are insured by the Federal Deposit Insurance Company ("FDIC"), has certain inherent risk. Please review and be aware of the following risk factors:

1. Generally speaking, brokered CDs, unlike CDs purchased directly from your bank, cannot be redeemed prior to maturity. Accordingly, if you later decide you want to cash in the CD prior to maturity, you will need to sell the CD on the secondary market. IB cannot guarantee that there will continue to be a secondary market for any CDs you purchase. Even if such a secondary market does continue to exist at the time you wish to sell, there may be very little liquidity available for your CD. If you do choose to sell you may incur a substantial loss as a result, in addition to incurring commissions on such transactions.
2. If market interest rates rise between the time you purchased the CD and the time you sell it, the market value of the CD can be expected to have declined, resulting in a loss of principal.
3. You should carefully read and understand any call features associated with any CD prior to purchasing it. Long-term CDs often include a provision that allows the issuer to call the CD prior to maturity at a specified price. The issuer is most likely to do this in an environment where market interest rates have declined since the CD's issuance.
4. Please note that the CD's offered for trading by Interactive Brokers are not FDIC-Insured.

Penny Stock Trading Risk Disclosure

This disclosure contains additional important information regarding the characteristics and risks associated with trading small-cap (penny) stocks.

What is a "Penny" Stock?

Generally, penny stocks are low-priced shares of small companies that are not traded on an exchange or quoted on NASDAQ. Penny stocks generally are traded over-the-counter, such as on the OTC Bulletin Board or Pink Sheets, and are historically more volatile and less liquid than other equities. For these and other reasons, penny stocks are considered speculative investments and customers who trade in penny stocks should be prepared for the possibility that they may lose their entire investment, or an amount in excess of their investment if they purchased penny stocks on margin. Before investing in a penny stock, you should thoroughly review the company issuing the penny stock. In addition, you should be aware of certain specific risks associated with trading in penny stocks.

Risks Associated With Penny Stocks

There are a number of risks of trading penny stocks, including the following:

You Can Lose All or Much of Your Investment Trading Penny Stocks. All investments involve risk but penny stocks are among the most risky and are generally not appropriate for investors with low risk tolerance. Many penny stock companies are new and do not have a proven track record. Some penny stock companies have no assets, operations or revenues. Others have products and services that are still in development or have yet to be tested in the market. Penny stock companies therefore have a greater risk of failure and those who invest in penny stocks have a greater risk that they may lose some or all of their investment.

Lack of Publicly Available Information. Most large, publicly-traded companies file periodic reports with the SEC that provide information relating to the company's assets, liabilities and performance over time. In addition, these companies provide their financial information and operational results online. In contrast, information about penny stock companies can be extremely difficult to find, making them more likely to be the subject of an investment fraud scheme and making it less likely that quoted prices in the market will be based on full and complete information about the company.

No Minimum Listing Standards. Companies that offer shares of their stock on exchanges can be subject to stringent listing standards that require the company to have a minimum amount of net assets and shareholders. Most penny stock companies do not list their shares on exchanges and are not subject to these minimum standards.

Risk of Lower Liquidity. Liquidity refers to the ability of market participants to buy and sell securities. Generally, the more demand there is for a particular security, the greater the liquidity for that security. Greater liquidity makes it easier for investors to buy or sell securities so investors are more likely to receive a competitive price for securities purchased or sold if the security is more liquid. Penny stocks are often traded infrequently and have lower liquidity. You may therefore have difficulty selling penny stocks once you own them. Moreover, because it may be difficult to find quotations for certain penny stocks, they may be difficult, or even impossible, to accurately price.

Risk of Higher Volatility. Volatility refers to changes in price that securities undergo when they are being traded. Generally, the higher the volatility of a security, the greater its price swings. Due to their lower liquidity, penny stocks are subject to greater volatility and price swings. A customer order to purchase or sell a penny stock may not execute or may execute at a substantially different price than the prices quoted in the market at the time the order was placed. In addition, the market price of any penny stock shares you obtain can vary significantly over time.

Penny Stocks Can Be Subject to Scams. Penny stocks are frequent vehicles for scams and/or market manipulation due to their generally lower prices and less stringent listing requirements. You should be wary of advertisements, unsolicited e-mails, newsletters, blogs or other promotional reports that emphasize the potential for large profits in penny stocks generally or certain penny stocks. These promotional materials are often used to manipulate or "pump up" the price of penny stocks before selling a large volume of shares. Customers are therefore strongly encouraged to do their own due diligence with respect to any penny stock company they invest in and to not rely on any outside promotional reports or newsletters.

Further information concerning penny stocks and the risks involved in trading them is available on the SEC's website at http://www.sec.gov/investor/pubs/microcapstock.htm.

Disclosure Regarding Interactive Brokers Pre-Borrow Program

Introduction: Interactive Brokers ("IB") offers eligible customers the ability to borrow shares in advance of selling such shares short (a "pre-borrow" transaction). Please read the following disclosure carefully for important information about the pre-borrow program.

Basic Nature of Transaction: When you pre-borrow shares through IB, you will be engaging in a securities borrowing transaction with IB as your counterparty and you will be charged an interest rate each day for the borrowed shares. The interest rate may change as often as daily based on changes in market conditions, changes in demand for the shares in the securities lending market, and other factors.

All Borrow Rates Are Merely Indicative Until Confirmed on Daily Statement; Rates May Change Daily: IB may provide indicative interest rates for pre-borrows, but such rates are indicative only and may be higher or lower by a material amount than the actual rate that you will be charged if you borrow securities, which will be determined at or near the end of the trading day and is subject to change each day thereafter.

By using the IB Trader Workstation or other means to initiate a pre-borrow transaction, you are agreeing to borrow securities for at least one day and you are agreeing to pay whatever interest rate IB charges you in its sole discretion for the loan of the securities (i.e., your request to pre-borrow shares is similar to a "market order"). The rate for your loan will be determined by IB based on a number of factors, including but not limited to demand in the securities lending market, rates charged to IB by its counterparties and borrowing and lending activity by other IB customers. After you have requested a pre-borrow and IB has confirmed the loan to you of the shares during the trading day, IB may provide you with an indicative rate for the loan. Again, this rate is only indicative and the final interest rate is subject to change and will not be determined until at or near the end of the trading day. The interest rate for each day and transaction is not final until it is reported to you on your daily IB statement.

Return of Borrowed Shares: If you wish to return shares after you have borrowed them, you may do so beginning on the next trading day (you cannot return borrowed shares on the same day as the original pre-borrow). In order to return shares on a given day and terminate the borrowing costs, you must initiate a return of the shares by the cut-off time specified on the IB website or by 10:50 a.m. Eastern U.S. time, whichever is earlier.

Pre-Borrow Transactions And Short Sale Transactions Are Separate And Independent: When you pre-borrow shares, the transaction does not automatically involve a short sale of such shares. You must engage in a separate short sale trade to open a short position. Likewise, if you pre-borrow shares and then sell the shares short, and later you cover the short sale by purchasing shares, this will not automatically extinguish the borrow transaction. I.e., you will still be borrowing the shares and in order to return them and stop paying interest for borrowing them, you must separately initiate a return of the borrowed shares using the Trader Workstation or other means specified by IB. If, after pre-borrowing shares, you do not sell them short for settlement within 5 days of the pre-borrow, IB may, but is not required to, terminate the loan and return the shares.

If you have an existing short sale position and you subsequently pre-borrow shares of the same security, IB may, but is not required to, use the pre-borrow to support the existing short position (depending on when and if you engage in other short sales).

No Guaranteed Term for Borrows; Borrowed Shares Subject to Recall at Any Time: Pre-borrowing shares does not give you the right to keep the borrowed shares for any specific period of time. The loan can be terminated by IB at any time and the borrowed shares will be taken from your account and returned. Among other reasons, this may happen if IB's external stock loan counterparties demand the shares back from IB. If you have pre-borrowed shares and then sold the shares short and IB thereafter terminates your borrow, this will not automatically terminate your short position (IB will not necessarily buy-in the shares you sold short). IB may be able to continue to provide shares to support your short position. If you pre-borrow shares and the loan is later terminated and if IB cannot otherwise find shares to continue to support your short position, you short position will be subject to being bought-in.

Commissions and Interest Rates: In addition to the interest rate you pay for borrowing shares, you will be charged a commission (at the commission rate described on IB's website) for each pro-borrow transaction. While IB will attempt to provide competitive interest rates for your pre-borrow transactions, IB does not guarantee that the rate will be the most favorable rate available. When you pre-borrow shares, IB may lend you shares it has available or may engage in separate transactions with external stock loan counterparties to support the loan to you. In either instance IB and/or its affiliates may earn a profit and/or a spread over market interest rates on the loan of shares to you.

Borrowing charges will be applied to your account on the same day that you initiate a pre-borrow transaction. This is true even though a short sale of those same shares will not settle until three days after the trade date. Thus, pre-borrowing before a short sale will lead you to incur several extra days of interest charges for the borrowed shares compared to an ordinary short sale done without a pre-borrow.

No Voting Or Other Rights: You will not have the right to vote, or to provide any consent or to take any similar action with respect to securities you borrow even if the record date or deadline for such vote, consent or other action falls during the term of the loan.

SIPC May Not Protect Pre-Borrowed Shares Prior to a Short Sale: Prior to using pre-borrowed shares for a short sale, such shares may not be protected under the provisions of the Securities Investor Protection Act of 1970.

FINRA Investor Protection Information Resources

Financial Industry Regulatory Authority ("FINRA") Conduct Rule 2267 requires that Interactive Brokers provide customers with certain information regarding its Public Disclosure Program. This information is included below:

The FINRA Public Disclosure (BrokerCheck) Program Hotline Number is (800) 289-9999.

The FINRA Website address is: http://www.finra.org

Customers who wish to obtain a brochure that describes FINRA BrokerCheck should contact FINRA at the phone number listed above or through the FINRA website.

Customer Consent to Receive Mutual Fund Information Electronically

In accordance with Customer’s consent to receive Electronic Records and Communications electronically pursuant to the IB Customer Agreement, Customer hereby consents to receive all mutual fund documents and information, including, but not limited to, prospectus’, statements of additional information, periodic statements and proxy solicitation materials (collectively, “Mutual Fund Information”), in electronic form. Mutual Fund Information may be sent to Customers via e-mail, or for security purposes may be posted on the IB website or a secure third-party website with an e-mail notification sent to the Customer regarding how to access and retrieve such information. Customer consents to receiving mutual fund prospectuses electronically, including via e-mail containing a link to the prospectus. Customer’s consent with respect to Mutual Fund Information will apply on an ongoing basis and for every tax year unless withdrawn by customer. Customer may withdraw such consent at any time by providing electronic notice to IB through the IB website. If Customer withdraws such consent, IB will provide required Mutual Fund Information in paper form to Customer. However, IB reserves the right to require Customer to close Customer’s account.

In the event a mutual fund held in Customer's account makes a dividend or capital gain distribution, Customer hereby consents to such dividend or capital gain distribution being reinvested in the distributing mutual fund. Should the Customer's account no longer be open at the point of dividend payment or capital gain distribution, Customer hereby consents to having the account credited with the equivalent of such dividend or capital gain distribution in the form of cash.

Interactive Brokers Group Privacy Policy

At Interactive Brokers, we understand that confidentiality and security of the personal information ("Personal Information") that you share with us is important. The Interactive Brokers Group affiliates (collectively, "IBKR"), are committed to protecting the privacy of Personal Information, including Personal Information related to individuals who may be clients, employees, agents, job applicants or others inside or outside of IBKR. That is why we have developed specific policies and practices designed to protect the privacy of your Personal Information. By opening an account at IBKR or by utilizing the products, services and applications available through IBKR, you have consented to the collection, use and disclosure of your Personal Information in accordance with this privacy policy ("Privacy Policy" or "Policy"). We encourage you to read this Privacy Policy carefully.

This Policy is based on the privacy and data protection principles common to the countries in which we operate. This Policy is intended to summarize IBKR's data protection practices generally and to advise our clients, prospective clients, job applicants, website visitors and other third parties about IBKR's privacy policies that may be applicable to them.

This Policy is specifically addressed to those who provide Personal Information to IBKR or who visit or use IBKR's websites, trading platforms, software application and social media sites.

Who is responsible for your Personal Information?

IBKR is responsible for the Personal Information that we may collect in the manner discussed below. IBKR includes: Interactive Brokers LLC, One Pickwick Plaza, Greenwich, CT 06830 United States; Interactive Brokers (U.K.) Limited, 20 Fenchurch Street, Floor 12, London, EC3M 3BY, United Kingdom; Interactive Brokers Ireland Limited, North Dock One, 91/92 North Wall Quay, Dublin 1 D01 H7V7, Ireland; Interactive Brokers Central Europe Zrt., 1075 Budapest, Madách lmre út 13-14., Hungary; Interactive Brokers Hong Kong Limited, Suite 1512, Two Pacific Place, 88 Queensway, Admiralty, Hong Kong SAR; Interactive Brokers Canada Inc., 1800 McGill College Avenue, Suite 2106, Montreal, Quebec, H3A 3J6, Canada and their respective affiliates (the "IBKR Entities"). Specifically, your Personal Information will be controlled by the IBKR Entity that is providing services or a communication to you. In some instances your Personal Information will be controlled by more than one IBKR Entity.

How do we collect your Personal Information and what Personal Information do we collect?

IBKR collects Personal Information from you. This may include, among other things, information:

• provided during the IBKR account application process or during use of any of IBKR's website applications (for example, your name, email address, telephone number, birth date, tax ID number, investment objectives, biometric information, etc.);
• provided when you apply for an employment opportunity with us (for example, your name, contact information and any additional information provided by you in your resume);
• acquired as a result of the transactions you conduct through the IBKR systems or in connection with services offered by IBKR (for example, if you participate in IBKR's debit card program);
• received from consumer-reporting agencies;
• collected through Internet cookies (for further information on our use of cookies, please see our Cookie Policy).

For what purposes will we use your Personal Information?

We may use your Personal Information for the following purposes ("Permitted Purposes"):

• To provide services to you in accordance with any agreement(s) you or your organisation may have with us, for our own administrative, record-keeping and compliance procedures;
• To provide you or your organisation with brokerage and other services available on our platforms, and/or to deal with any requests or inquiries you may have;
• To pursue legitimate interests, including to carry out, monitor and analyze our business or operations including the activities set out in this Privacy Policy;
• To enforce or apply any agreement and/or to protect our (or others') property or rights and to defend any potential claim;
• To conduct our recruiting processes (applies only to information submitted for employment applications);
• To respond to requests for information from you and to follow up with you afterwards to see if we can provide any further assistance;
• To contact you (unless you tell us that you prefer us not to) regarding features and functionality that may be of interest to you;
• To enter into or carry out contracts of various kinds;
• To conduct monitoring by us or any other person on our behalf using various methods, including: (i) the use of "intelligent" automated monitoring tools; or (ii) through random monitoring of systems, for example systematically via electronic communication recording tools; (iii) specific monitoring of systems for example in relation to investigations, regulatory requests, subject access requests, litigation, arbitration or mediation or; (iv) data tracking, aggregation and analysis tools that pull data from various disparate data sources to draw linkages and/or detect behavioral patterns, interactions or preferences for analysis (including predictive analysis); and/or (v) using other similar monitoring technology that may become available from time to time;
• For statistical purposes and for market research and product analysis and to develop and improve our products and services;
• For the purposes of preventing and detecting money-laundering, terrorism, fraud or other crimes and/or abuses of our services;
• To comply with any legal, regulatory or good practice requirement whether originating from Ireland or elsewhere (including but not limited to, the United States), and to fulfil our obligations under any reporting agreement entered into with any tax authority or revenue service(s) from time to time;
• To comply with applicable laws in any country.

We may also process your Personal Information for the following purposes (after obtaining your express consent where such consent is legally required) in accordance with your preferences:

• To communicate with you through the channels you have approved to keep you up to date on the latest developments, announcements and other information about IBKR services, products and technologies;
• To conduct client surveys, marketing campaigns, market analysis, or promotional activities;
• To collect information about your preferences to create a user profile to personalize and foster the quality of our communication and interaction with you (for example, by way of newsletter tracking or website analytics).

Where legally required, with regard to marketing-related communication, we will only provide you with such information after you have opted in or had an opportunity to object and we will also provide you with the opportunity to opt out at any time if you do not wish to receive further marketing-related communication from us. We like to keep our clients, personnel and other interested parties informed of company developments, including news relating to IBKR that we believe is of interest to you. If you do not wish to receive publications or details of events or seminars that we consider may be of interest to you, please let us know by following this link: https://www.interactivebrokers.com/en/index.php?f=464. Where legally required, we will not use your Personal Information for taking any automated decisions affecting you or creating profiles other than described above.

Depending on which of the above Permitted Purposes we use your Personal Information for, we may process your Personal Information on one or more of the following legal grounds:

• Because processing is necessary for the performance of your instruction or other contract with you or to take steps prior to entering into any such contract;
• To comply with our legal obligations (for example, to keep pension records or records for tax purposes);
• Because processing is necessary for the purposes of our legitimate interest or those of any third party recipients that receive your Personal Information, provided that such interests are not overridden by your interests or fundamental rights and freedoms.

In addition, the processing may be based on your consent where we have expressly sought and you have expressly given that to us.

Who we share your Personal Information with, and in what circumstances

We share your Personal Information in the following circumstances:

• We may share your Personal Information between the IBKR Entities on a confidential basis as allowed by applicable law or where required for the purpose of providing products or services and for administrative, billing and other business purposes. A list of the countries in which IBKR Entities are located can be found on our website;
• We instruct service providers within and outside of IBKR (including cloud service providers such as AWS), domestically or abroad, to process Personal Information for the Permitted Purposes on our behalf and in accordance with our instructions and based on our legitimate interest to provide, maintain and improve our products and services. For example, if you choose to subscribe to any services provided by a third-party provider listed on an Interactive Brokers Investors' Marketplace, we may disclose such information to service providers as necessary for them to provide the services that you have requested. IBKR generally requires these service providers to enter into confidentiality agreements with IBKR that limit their use of the information that they receive. Such agreements prohibit the service provider from using IBKR client information that they receive other than to carry out the purposes for which the information was disclosed. If required by law, IBKR will retain control over and will remain responsible for your Personal Information and will use appropriate safeguards to ensure the integrity and security of your Personal Information when engaging service providers;
• We may share your Personal Information with companies providing services in the areas of fraud and crime prevention and with companies providing similar services, including financial institutions such as credit reference agencies and regulatory bodies;
• We may disclose information about you to any depository, stock exchange, clearing or settlement system, account controller or other participant in the relevant system, to counterparties, dealers, custodians, intermediaries and others where disclosure is reasonably intended for the purpose of effecting, managing or reporting transactions in connection with the provision of our services or establishing a relationship with a view to such transactions;
• We may share data provided to us for employment applications with third parties to assist us with the conduct of our recruitment processes;
• Consistent with applicable law, we may share your Personal Information with courts, law enforcement authorities, regulators or attorneys or other parties for the establishment, exercise or defence of a legal or equitable claim or for the purposes of a confidential alternative dispute resolution process;
• We may also use aggregated Personal Information and statistics for the purpose of monitoring website usage in order to help us develop our website and our services.

Otherwise, we will only disclose your Personal Information when you direct us or give us permission to do so, when we are allowed or required by applicable law or judicial or official request to do so, or as required to investigate actual or suspected fraudulent or criminal activities.

Personal Information about other people that you provide to us

If you provide Personal Information to us about someone else (such as one of your directors or employees or someone with whom you have business dealings), you must ensure that you are entitled to disclose that Personal Information to us for processing as described in this Privacy Policy.

Keeping Personal Information about you secure

To the extent required by law, we will take appropriate technical and organizational measures to keep your Personal Information confidential and secure in accordance with our internal procedures covering the storage, disclosure of and access to Personal Information. Personal Information may be kept on our Information Technology systems, those of our contractors or in paper files.

Transferring your Personal Information outside the European Economic Area ("EEA") or the United Kingdom (if GDPR or UK GDPR applies).

For Personal Information subject to the General Data Protection Regulation (EU) 2016/679 ("GDPR") or the UK General Data Protection Regulation ("UK GDPR") we may transfer your Personal Information outside the EEA or the United Kingdom (the "UK") for the Permitted Purposes as described above. This may include countries that do not provide the same level of protection as the laws of your home country (for example, the laws within the EEA, the UK or the United States). We will ensure that any such international transfers are made subject to appropriate or suitable safeguards if required by the GDPR, UK GDPR or other relevant laws. You may contact us at any time using the contact details below if you would like further information on such safeguards.

With respect to persons covered by GDPR, in case Personal Information is transferred to countries or territories outside of the EEA, or in the case of UK GDPR outside of the UK, that are not recognized by the European Commission as offering an adequate level of data protection, we have put in place appropriate data transfer mechanisms to ensure Personal Information is protected.

Updating your Personal Information

If any of the Personal Information that you have provided to us changes, for example if you change your email address or if you wish to cancel any request that you have made of us, please let us know by contacting IBKR Client Service through the IBKR website at ibkr.com/help. We will not be responsible for any losses arising from any inaccurate, inauthentic, deficient or incomplete Personal Information that you provide to us.

How long do we retain your Personal Information?

We retain your Personal Information in an identifiable form in accordance with our internal policies which establish general standards and procedures regarding the retention, handling and disposition of your Personal Information. Personal Information is retained for as long as necessary to meet legal, regulatory and business requirements. Retention periods may be extended if we are required to preserve your Personal Information in connection with litigation, investigations and proceedings.

Further rights for persons or information covered by GDPR, UK GDPR and the Personal Information Protection Law ("PIPL")

With respect to residents of the EEA, the UK and the People's Republic of China ("PRC"), as well as in situations where your Personal Information is processed by an IBKR Entity established in the EEA, or the UK ("Covered Individuals"), you have a number of legal rights under GDPR, UK GDPR and/or PIPL in relation to the Personal Information that we hold about you. These rights include:

• Obtaining information regarding the processing of your personal information and access to the personal information that we hold about you. Please note that there may be circumstances in which we are entitled to refuse requests for access to copies of personal information, (in particular, information that is subject to legal professional privilege);
• Requesting that we correct your personal information if it is inaccurate or incomplete;
• Requesting that we erase your personal information in certain circumstances. Please note that there may be circumstances where you ask us to erase your personal information but we are legally entitled to retain it;
• Objecting to, and requesting that we restrict, our processing of your personal information in certain circumstances. Again, there may be circumstances where you object to, or ask us to restrict, our processing of your personal information but we are legally entitled to refuse that request;
• Withdrawing your consent, although in certain circumstances it may be lawful for us to continue processing without your consent if we have another legitimate reason (other than consent) for doing so.

We have designated a Data Protection Officer ("DPO") to enhance and promote compliance with and understanding of privacy and data protection principles. If you wish to do any of the above please send an email to dpo@ibkr.com.

We may request that you prove your identity by providing us with a copy of a valid means of identification in order for us to comply with our security obligations and to prevent unauthorized disclosure of data. We reserve the right to charge you a reasonable administrative fee for any manifestly unfounded or excessive requests concerning your access to your data and for any additional copies of the Personal Information you request from us.

We will consider any requests or complaints that we receive and provide you with a response in a timely manner. If you are not satisfied with our response, you may take your complaint to the relevant privacy regulator. We will provide you with details of your relevant regulator upon request.

Notice to California Residents: As a federally-regulated provider of financial services, IBKR is broadly exempt from the California Consumer Privacy Act ("CCPA"). Personal information we collect from clients and prospective clients is protected under separate federal legislation. Over the past 12 months, the only type of information we have collected potentially subject to the CCPA is web-browsing information regarding passive visitors to our website who are California residents, but are not our clients and do not provide us with any specific personal information (name, email address, street address, social security number, etc.) to request information about our services, start an account application or become a client. Information collected from these anonymous, passive visitors to our website may include IP address and browser-specific tags. We do not sell this information to third parties. We only use this information for internal purposes, such as to determine which advertisements are working and which content on our website is most interesting to visitors. Under the CCPA, California residents connected to this type of web-browsing data have a right to request access to it or request that it be deleted. However, we are unable (and not required) to process such requests because we cannot connect such passive web-browsing information collected with an email address or other personal information that we can use to verify that a requesting party is in fact connected to a specific web-browser or IP address.

Updates to this Privacy Policy

This Privacy Policy was last updated on the date indicated at the top of this Policy. We reserve the right to update and change this Privacy Policy from time to time, for example, in order to reflect any changes to the way in which we process your Personal Information or changing legal requirements. In case of any such changes, we will post the changed Privacy Policy on our website or publish it otherwise. The changes will take effect as soon as they are posted on our website.

How to contact us

We welcome your views about our website and our Privacy Policy. If you have any questions about this Policy, please contact the Data Protection Officer at dpo@ibkr.com or please contact IBKR Client Services through the IBKR website at ibkr.com/help.

Interactive Brokers Business Continuity Plan Disclosure

1. Introduction
   

   In accordance with applicable regulations, Interactive Brokers ("IB") has developed a Business Continuity Plan to assist the firm in appropriately responding to a significant business disruption as promptly as possible under prevailing conditions. Among other things, IB's Business Continuity Plan:

   • Identifies Emergency Contact Personnel to the firm's regulators;
   • Describes the systems infrastructure protections that the firm has established in an effort to minimize the potential adverse effects of a disruption (for example, redundancy of telecommunications and power generation, fire protection and building security);
   • Describes the firm's daily back-up of specified data and records and maintenance of back- up media at secure off-site locations;
   • Describes the firm's continuity of operations plan and the methods that the firm would use to recover particular data and operations;
   • Identifies important firm operations and where applicable, describes how those operations could be re-established in the event of a disruption;
   • Identifies the means by which the firm will provide clients prompt access to their funds and securities and/or the ability to transfer their funds and positions to another broker or futures commission merchant in the event of a disruption of such magnitude that IB does not intend to continue business; and
   • Describes the means by which the firm will communicate with its clients, employees, business constituents and regulators in the event of a disruption.

   In the event of a significant business disruption, the firm intends to continue its operations to the extent reasonable and practical under the circumstances and will place utmost priority in re- establishing the data and operational systems necessary to provide its clients with prompt access to their funds and securities.

   The firm intends to respond to disruptions of the scopes discussed below in the following ways:



2. Basic Access to Funds and Office Disruption
   

   Securities in the Event of a Branch Office Disruption: Critical systems and personnel necessary to provide clients with access to their funds and securities generally are not dependent on operation of IB's branch offices (e.g., Chicago, London, Hong Kong and Zug, Switzerland). Thus, the firm does not anticipate that even a significant disruption to the operations of a single IB branch office would have more than a temporary impact,if any, on clients' basic access to their funds and securities.

   Connection to IB Trading System for certain Clients: Clients that connect to the IB online trading system (e.g., the IB Trader Workstation) through a data center that suffers a disruption likely would temporarily lose the ability to connect to the trading system if those local systems were significantly disrupted. This likely would last only briefly, as connections to IB's trading systems and exchange access could be reestablished through other IB data centers in a matter of hours. Regardless, clients would still have the ability to place trades by telephone during the temporary outage. Most clients' access to account functions other than trading (e.g., deposits and withdrawals, account management, etc.) likely would be unaffected, as connections for many online functions other than trading are generally not location-dependent.

   As specified in the IB Customer Agreements, clients should maintain alternative trading arrangements in addition to their IB accounts for the placement and execution of client orders if the IB system is unavailable. By not maintaining alternative trading arrangements, clients assume the risk of not being able to execute trades or otherwise process transactions through their IB account in the event of a delay, interruption or failure of IB's services and systems.

   Operating Model Resiliency: Most critical manual operations performed in IB offices, such as Client Service, Risk Management, Finance, Compliance, etc. are also performed in other IB offices and can generally be migrated to personnel in other offices. Accordingly, the firm does not anticipate that localized failures would have a material, prolonged impact on the firm's ability to respond to client needs.



3. Headquarters or Primary Data Center Disruption:
   

   The firm has designed its systems, procedures and personnel structure to include significant redundancy and cross-capability in the event of a disaster or disruption impacting its Headquarters or one of its Primary Data Centers.

   In the Event of a Disruption at IB's Primary Data Centers: The firm's primary data centers operate on a generally redundant basis so that disruptions affecting communications lines, computer hardware components, or systems, can typically be addressed within one day, hopefully sooner, through the use of redundant systems.

   In the event of a total loss of one of the firm's primary data centers, the firm intends to recover the relevant data and operational systems necessary to provide clients prompt access to their funds and positions. IB's data centers are in geographically diverse locations that should not be subject to the same communications, electricity and/or transportation restrictions.

   During the immediate aftermath of, for example, a terrorist attack resulting in the destruction of the firm's Greenwich headquarters or a primary data center, the firm expects to recover most critical services, such as Brokerage, Account Management, and Funds and Banking, to another of our data centers and establish basic client access to funds and positions within approximately 24 hours, hopefully sooner. We anticipate that, after this window, clients would be able to request a withdrawal of funds or transfer of their positions to another broker whose operations were unaffected by, for example, the terrorist attack. Although IB's Business Continuity Plan is designed to provide client access to funds and positions within 24 hours, hopefully sooner, the actual recovery time will depend on the nature of the disruption, how many IB facilities and personnel are affected, the state of the national and global financial and banking system, and a host of other factors. Non-critical systems and services may require longer to recover, as critical systems will take priority.

   In the Event of a Disruption at IB's Headquarters: The firm has significant capacity and capability in its global offices, both in terms of systems and personnel, to help mitigate any disruptions in IB's headquarters. The firm has a robust infrastructure in place to support all key staff working remotely in the event that office locations, including the firm's Headquarters, are inaccessible.

   In the event of a significant disruption or IB's systems the firm anticipates that clients may be able to access status.interactivebrokers.net to obtain information about the extent of the disruption and the state of IB's operations. Because most client services personnel are in offices other than at IB headquarters, the firm anticipates that clients would continue to be able to contact the firm via chat, email or telephone. In the event of a significant outage or major terrorist or other disaster affecting the markets, large numbers of clients likely would try to contact the firm at the same time, potentially causing major delays in our ability to respond.



4. Important Disclaimers
   

   The firm will adhere to the procedures set forth in its Business Continuity Plan and described in this disclosure to the extent commercially reasonable and practicable under prevailing circumstances. Disruptions may vary significantly in nature, size, scope, severity, duration and geographic location and will result in distinct degrees of harm to human life; firm assets; banks, exchanges, clearing houses and depositories with which the firm conducts business; and local, regional and national systems infrastructure (e.g., telecommunications, internet connectivity, power generation and transportation) that could affect the firm's recovery in vastly disparate ways. The firm therefore reserves the right to flexibly respond to particular emergencies and business disruptions in a situation-specific manner which the firm deems prudent, in its sole discretion. Nothing in this document is intended to provide a guarantee or warranty regarding the actions or performance of the firm, its computer systems, or its personnel in the event of a significant disruption.

   The firm may modify its Business Continuity Plan and this disclosure at any time. The Firm will post updates to its Business Continuity Plan Disclosure on its website. Should you wish to receive a copy of an updated disclosure by mail, please contact the IB Document Processing Department at newaccounts@interactivebrokers.com.

Nasdaq ISE Disclosure for Option Orders Over 500 Contracts

Interactive Brokers is required to provide to you the following disclosure regarding option orders of over 500 contracts that may be executed using the Nasdaq ISE (ISE) Block Order Solicitation Mechanism:

When handling an order of 500 contracts or more on your behalf, Interactive Brokers may solicit other parties to execute against your order and may thereafter execute your order using the ISE's Solicited Order Mechanism. This functionality provides a single price execution only, so that your entire order may receive a better price after being exposed to the Exchange's participants, but will not receive partial price improvement. For further details on the operation of this Mechanism, please refer to Nasdaq ISE Rule Options 3, Section 11, which is available at https://listingcenter.nasdaq.com/rulebook/ise/rules.

Notice Regarding USA Patriot Act Section 311

Pursuant to U.S. regulations issued under Section 311 of the USA PATRIOT Act, Interactive Brokers will require additional special measures for customers establishing, maintaining, administering or managing an account for, or on behalf of any Section 311 entities. The most recent listing of 311 entities as promulgated by FinCEN, as of March 30, 2021, is as follows:

• ABLV Bank, AS
• Bank of Dandong
• Any bank or financial institution of Burma
• Commercial Bank of Syria (includes Syrian Lebanese Commercial Bank)
• Any bank or financial institution of the Democratic People's Republic of Korea
• FBME Bank Ltd.
• Halawi Exchange Co.
• Any bank or financial institution of the Islamic Republic of Iran
• Kassem Rmeiti & Co for Exchange

Any customers involved with 311 entities will be subject to further review and determination on whether Interactive Brokers will continue the relationship. Additionally, your account with Interactive Brokers may not be used to provide services for the above that would violate other U.S. regulations.

Interactive Brokers may, from time to time, update this notice to include jurisdictions or entities that are added to FinCEN's Section 311 list. Current listings of entities subject to final or proposed rules under Section 311 can be found on the FinCEN website.

Risk Disclosure Regarding Short Selling of Mexican Stocks

There are risks associated with short selling Mexican stocks that may expose you to significant losses. This strategy is not suitable for all customers. Please read the following carefully:

1. Selling stock short is a risky strategy for investors.
   
   
   • There is unlimited risk when shorting stock as stocks may continue to increase in price indefinitely.
   • There is risk that the company will effect a corporate action while you are short the stock and you will be responsible for paying for any dividends or other distributions.
2. Short sales must be done in a margin account and are subject to IB's margin requirements.
3. Prior to selling short, IB must confirm that it can locate shares of the stock to borrow for delivery. Any fees incurred by IB for borrowing stock on your behalf will be passed on to you.
4. If IB cannot borrow stock (or re-borrow after a recall notice from the lender) IB may buy shares of stock on your behalf to cover short positions and you will be liable for any losses/costs.
5. Borrowing stock requires that you post collateral. The lender and IB determine which type of assets may be posted as Collateral. Collateral is returned to you when the shares are returned to the lender.
6. The lender of the shares reserves the right to recall the shares at any time. Should a recall of shares occur, IB will attempt to replace the previously borrowed shares with shares from another source. If IB is unable to borrow sufficient shares, IB reserves the right to buy shares on your behalf to cover short positions. Additionally, the lender may execute a buy-in transaction in the marketplace and notify IB of the execution price. IB, in turn, allocates the buy-in to customers based upon their settled short stock position. You will be liable for any losses/costs.
7. Based on the manner in which a buy-in may be required to be executed, significant differences between the price at which the buy-in transaction was executed and the prior day's close may result. These differences may be especially pronounced in the case of illiquid securities.
8. Based on the manner in which a buy-in and a third party is allowed to execute a buy-in, significant differences between the price at which the buy-in transaction was executed and the prior day's close may result. These differences may be especially pronounced in the case of illiquid securities.
9. Short positions are subject to liquidation to meet any margin deficiency that may arise in your account(s) and IB may not provide notice prior to such liquidation.

Debit Card Supplement to Interactive Brokers LLC Customer Agreement

This Supplement (the "Supplement") to the Interactive Brokers LLC Customer Agreement is made between Customer and Interactive Brokers LLC ("IB") and sets forth the conditions under which IB agrees to permit Customer to participate in the Interactive Brokers Debit Mastercard ("Card") program, under which a debit card will be issued to Customer by Metropolitan Commercial Bank ("MCB" or "Bank"). Customer agrees to be legally bound by the terms and conditions set forth in this Supplement. This Supplement is solely between IB and Customer, and nothing in this Supplement shall amend, supplement, vary, or otherwise change or replace the terms and conditions governing the relationship between MCB and Customer, as set forth in the Interactive Brokers Debit Mastercard Cardholder Agreement ("Cardholder Agreement") between MCB and Customer.

Customer understands and agrees that Customer continues to remain bound by the terms and conditions of the Interactive Brokers LLC Customer Agreement (as amended from time to time, the "Customer Agreement") which governs Customer's securities brokerage account at IB ("Brokerage Account"), of which this Supplement forms a part (such Customer Agreement, together with this Supplement and any other supplements, annexes, schedules or exhibits, the "Agreement"), and that all terms and conditions in the Customer Agreement, including, without limitation, the "Mandatory Arbitration" provision thereof, shall also govern the relationship between IB and Customer with regard to any services in connection with the Card and any other service, transaction or relationship contemplated by this Supplement. Unless otherwise defined, capitalized terms used but not defined in this Supplement shall have the meanings assigned in the Customer Agreement.

1. Definitions: As used in this Supplement:
   
   
   1. "You" shall mean the Customer to whom the Card is issued.
      
      
   2. "We" or "us" shall mean IB.
      
      
2. General Features of Services: The Card allows you to make charges in, and withdraw cash from, your Card Account. "Card Account" means your beneficial interest in the pooled deposit account at MCB held by IBKR on behalf of its customers in connection with their respective Cards. You instruct us to link your Brokerage Account to your Card Account and to automatically fund your Card Account as needed to settle transactions made with your Card. As a result, and for your convenience, any credits, charges or withdrawals posted to your Card Account will be reflected as identical credits, charges or withdrawals to your Brokerage Account. Your Brokerage Account will automatically fund the Card Account from available cash balances in your Brokerage Account (the "Available Cash Balance"). In addition, if your Brokerage Account is a margin account, your Brokerage Account will automatically fund your Card Account (to the extent that you do not have an Available Cash Balance) by incurring a new margin debit in your Brokerage Account, up to your cash withdrawal limit, pursuant to the terms of your Customer Agreement (the "Margin Spending Limit" and as added to your Available Cash Balance, your "Spending Power").
   
   
3. Available to Withdraw: Your Spending Power may fluctuate from day to day because it is dependent upon changes in the Available Cash Balance (and, in the case of margin accounts, available Margin Spending Limit) in your Brokerage Account. Shortly after IB is notified of a transaction, your Spending Power is reduced. You promise not to make a transaction (such as making a purchase with your Card or withdrawing cash at an ATM) that exceeds your Spending Power. If you attempt to make a transaction that will exceed your Spending Power, the transaction will normally be declined. If, for any reason, such transaction is not declined, you agree to be responsible for such transaction to the full extent permitted under the Cardholder Agreement between you and the Bank.
   
   
4. Payment for Transactions: On a daily basis, IB will receive notice of the transactions on your Card Account. Funds will automatically be withdrawn from your Brokerage Account and deposited into the Bank Deposit Sweep Program (the "Program") at MCB (refer to the section below titled "Bank Deposit Sweep Program" for more information) to satisfy the debits made in your Card Account (whether with your Card or otherwise) that are settling that day. IB will make payments to the Program on your behalf on each Business Day (Monday through Friday, excluding federal and legal banking holidays in the State of New York) that IB receives notice of settling transactions. You authorize IB to charge your Brokerage Account in order to fund your Card Account in order to pay for transactions that you make. Each transaction shall be considered to be your direction to us to charge your Brokerage Account in order to fund your Card Account. When you use your Card, the charge or reduction to your Spending Power generally occurs immediately. You understand that Authorizations, transactions in which you authorize others to place a hold on your Spending Power to ensure future payment, will reduce your Spending Power by the amount of the Authorization even if the Authorization does not result in a transaction. Note that an Authorization will reduce your Spending Power until the transaction is completed in whole or in part, or if it is not completed, after the expiration of a time period specified by us.
   
   
5. Payment of Items: All Card transactions will be accumulated daily, and charged to your Brokerage Account in any order we may choose. We will debit your Brokerage Account on the day a transaction settles in the transaction amount, including any fees or other charges associated with the transaction. If you do not have a sufficient Available Cash Balance at the time a transaction settles, we will settle the transaction by increasing your current margin debit (if any). You understand that margin transactions carry substantially increased risk, including the risk that we will be obligated to liquidate your Brokerage Account in part or whole if your Brokerage Account falls below its minimum maintenance margin level, and that you will be charged interest on any margin debit you incur. You understand that IB generally will not issue margin calls in connection with margin deficiencies and that you may not be able to transfer funds into your Brokerage Account quickly enough to prevent liquidation in the event that your Brokerage Account falls below maintenance margin requirements on either an intraday or overnight basis. Please read the section of your Customer Agreement titled "Margin" for more details about the risks of margin trading and IB's policies in connection with margin deficits, margin calls, and liquidation.
   
   
6. Loss, Theft or Unauthorized Transaction: You should tell us AT ONCE (by calling 1-866-532-4654) if you believe your Card has been lost or stolen or if you believe an unauthorized person may know the personal identification number ("PIN") associated with your Card. Similarly, tell us, as agent for MCB, if you believe any unauthorized transactions have been made in your Card Account. Your Cardholder Agreement with MCB sets your rights and obligations with respect to your use of your Card, including your liability for unauthorized transactions.
   
   
7. Authorized Users: You may request an additional Card ("Supplementary Card") to allow another person to make withdrawals from and incur charges to your Card Account. If you permit another person to have access to your Card or Card Number (the 16-digit number on your Card), or to receive a Supplementary Card, you are wholly responsible for such person's use of any such Card according to the terms and conditions set forth in your Cardholder Agreement with MCB.
   
   
8. Bank Deposit Sweep Program: As a condition of receiving a Card, you agree to participate in our bank deposit sweep Program with MCB. Agreeing to this Supplement and receiving a Card automatically enrolls your Brokerage Account in the Program. For purposes of administering the Program, you appoint us as your authorized agent and custodian and acknowledge and agree that we may engage third parties (including affiliates) to act on our behalf or on your behalf with respect to the Program. Currently, no bank will accept any instructions concerning your cash on deposit with MCB, the destination bank, unless such instructions are transmitted by us.

   Cash is deposited from your Brokerage Account into the Program solely for the purpose of settling debits in your Card Account. Cash deposited in the Program will generally only remain in the Program intraday. The Program is not intended to be an interest-bearing service, but to solely function as a means for settling debit entries in your Card Account. Cash transferred from your Brokerage Account to your Card Account, while it is deposited with MCB is a bank deposit and such deposit is solely the obligation of MCB and not us. We act only as agent and custodian for your deposit and you are the depositor. The cash deposited in your Card Account as a result of Card transaction authorizations will be used by MCB to settle such transactions with the various Card networks in which your Card participates as well as to pay any applicable fees as specified by your Cardholder Agreement. We inform you as of the end of each calendar month as part of your Brokerage Account statement the amount of cash MCB holds on deposit on your behalf in your Card Account as a result of your participation in the Program.

   MCB is the depository institution duly chartered under New York state law, the deposits of which are insured by the FDIC. We are a broker-dealer registered with the U.S. Securities and Exchange Commission ("SEC") and a member of the Financial Industry Regulatory Authority, Inc. ("FINRA"). We are not a bank. All cash in your Card Account under the Program is deposited in an FDIC-insured account at MCB. Any cash in your Card Account on deposit with MCB is not covered by the Securities Investor Protection Corporation (SIPC) protection applicable to your Brokerage Account.

   With prior notice to you and, if then required by applicable law or regulation, with your consent, we can change the features or products that are included in the Program to include any legally permissible deposit account or instrument or we can terminate any or all of the products in the Program and hold some or all of your cash only as a positive cash balance in your Brokerage Account. We may in our sole discretion, for any reason we deem appropriate and without prior notice, restrict participation of your Brokerage Account in the Program or decline to permit your Brokerage Account from participating in the Program at any time on a going forward basis. You understand that if we do so, this will generally result in a termination of your Card privileges and of any other services contemplated by this Supplement.

9. Account Statements: IB will send you a Brokerage Account statement every month in which a transaction was made. In any case, you will get a Brokerage Account statement at least quarterly. Daily Activity Statements will generally be available for your Brokerage Account on the next business day, and will reflect pending as well as settled debit card transactions. MCB will not send you a separate periodic statement. You should review your statement and receipts carefully, and promptly notify us of any discrepancy between your records and what is reflected on your statement.
   
   
10. Authorization to Share Information With Third Parties: We will not reveal any information to third parties about your Brokerage Account or any transaction information we receive from MCB, as provided in your Cardholder Agreement with MCB, EXCEPT: (1) you hereby authorize us to share information concerning your transactions with our affiliates and agents for the purpose of servicing your Card; (2) where it is necessary for completing your transactions or providing you other services; (3) to other persons and entities in order to resolve disputes arising from transactions; or (4) in any other circumstances contemplated by our Privacy Policy, as furnished to you separately and updated or amended from time to time by us.
    
    
11. Nature of Obligations: The obligations of IB as they relate to your Card are set forth in this Supplement. Your Cardholder Agreement with MCB sets forth MCB's obligations in connection with your Card as well as your obligations in connection with your Card. IB is not liable for the obligations of MCB, nor is MCB liable for the obligations of IB.
    
    
12. Other Terms: Use of your Card is subject to all terms of your Cardholder Agreement with MCB. We do not waive our rights by delaying or failing to exercise them at any time. If any provision of this Agreement shall be determined to be invalid or unenforceable under any applicable rule, law, or regulation of any regulatory agency, whether local, state, federal, securities SRO or otherwise, the validity or enforceability of any other provision of this Agreement shall not be affected.
    


13. Notices: Notices and other communications relating to your Brokerage Account in connection with your use of your Card (including, without limitation, communications relating to your Spending Power) will be provided electronically in accordance with your Customer Agreement.
    
    
14. Termination of Card Services: IB or you may terminate the services contemplated under this Supplement, including the use of Cards, at any time. You shall remain responsible for authorized charges that arise before or after termination. In the event of termination for whatever reason, you shall promptly destroy all Cards.
    
    
15. Disputes Involving Your Account: This Supplement shall be treated for all purposes as forming a part of the Customer Agreement. Any dispute between you and IB, arising from any of the services contemplated by this Supplement, shall be governed by the pre-dispute mandatory arbitration provision of the Customer Agreement. Your Cardholder Agreement with MCB may contain different dispute resolution provisions, which may apply to disputes between you and MCB and other parties covered by that agreement but do not apply to disputes between you and IB.
    

THE CUSTOMER AGREEMENT, WHICH THIS SUPPLEMENT FORMS A PART OF, CONTAINS A PRE-DISPUTE ARBITRATION CLAUSE IN PARAGRAPH 34. BY SIGNING THIS SUPPLEMENT, I ACKNOWLEDGE THAT THIS AGREEMENT CONTAINS A PRE-DISPUTE ARBITRATION CLAUSE AND THAT I HAVE RECEIVED, READ AND UNDERSTOOD THE TERMS THEREOF.

Direct Debit Supplement to Interactive Brokers LLC Customer Agreement

This Supplement (the "Supplement") to the Interactive Brokers LLC Customer Agreement is made between Customer ("you") and Interactive Brokers LLC ("IBKR", "we", or "us") and sets forth the conditions under which IBKR agrees to permit you to direct debit funds from your IBKR brokerage account ("Brokerage Account") via an external account at a U.S. bank or other U.S.-resident financial institution ("External Account") using the Automated Clearing House (ACH) network (the "Service"). You agree to be legally bound by the terms and conditions set forth in this Supplement.  

You understand and agree that you continue to remain bound by the terms and conditions of the IBKR Customer Agreement (as amended from time to time, the "Customer Agreement") which governs your Brokerage Account, of which this Supplement forms a part (such Customer Agreement, together with this Supplement and any other supplements, annexes, schedules or exhibits, the "Agreement"), and that all terms and conditions in the Customer Agreement, including, without limitation, the "Mandatory Arbitration" provision thereof, shall also govern the relationship between IBKR and you with regard to the Service and any other service, transaction or relationship contemplated by this Supplement. Unless otherwise defined, capitalized terms used but not defined in this Supplement shall have the meanings assigned in the Customer Agreement.

1. General Features of the Service: Through the Service, you may instruct another U.S. financial institution or payment system (the "External Correspondent") to direct debit your Brokerage Account in a specified amount for the benefit of an External Account, and that debit will be submitted to IBKR through its agent bank by the External Correspondent for payment via the ACH network (a "Direct Debit"). Direct Debits may be withdrawn up to the available cash balance in your Brokerage Account (the "Available Cash Balance"), subject to any limits under Section 7 of this Supplement. In addition, if your Brokerage Account is a margin account, to the extent that you do not have sufficient Available Cash Balance, your Brokerage Account will automatically make available funds, by incurring a new margin debit in your Brokerage Account, up to your cash withdrawal limit (subject to any limits under Section 7 of this Supplement), pursuant to the terms of your Customer Agreement (the "Margin Spending Limit" and as added to your Available Cash Balance, your "Spending Power").
   
   
2. ACH Authorization: You hereby authorize IBKR to (i) honor Direct Debit instructions received via the ACH network by our agent bank with respect to your Brokerage Account (a remotely-initiated transfer of funds from your Brokerage Account to an External Account) and (ii) initiate returns of erroneous, unauthorized, or duplicate Direct Debit entries or Direct Debit entries that exceed your Spending Power. This authorization will remain in full force and effect until IBKR has received written notification from you of its termination. IBKR must receive this notification of termination in a time and manner so as to give IBKR and the other financial institutions a reasonable opportunity to act on your instructions.
   
   We will send you a notification in writing (a "Debit Notice") anytime we receive a Direct Debit request for your Brokerage Account. Currently, we will send Debit Notices by SMS text message. In the future we may offer other ways to receive Debit Notices. We may add such other methods to the terms of this Agreement at any time by notifying you in writing or by providing notice on our website at www.ibkr.com of such change.
   
   You should immediately review any Debit Notice you receive from us. If you do not recognize the transaction in any such Debit Notice, you should notify us immediately (but in any event no later than 2pm Eastern Time on the Business Day (Monday through Friday, excluding federal and legal banking holidays) following the day of our Debit Notice) by cancelling the transaction via the functionality in your IBKR mobile app on your smartphone ("IBKR Mobile"). We may provide alternative means to cancel a Direct Debit in the future. We will notify you in writing or provide notice on our website of any such alternative mechanism (the term IBKR Mobile, as used below, shall encompass any such alternative mechanism as well), and such notice shall serve to amend the terms of this Agreement to encompass such alternative method.
   
   If we receive a Direct Debit request for your Brokerage Account in excess of a certain threshold dollar value (the "Threshold Amount"), we will automatically reject such request unless you explicitly authorize and approve such specific Direct Debit via IBKR Mobile by no later than 2pm Eastern Time on the Business Day following the day of our Debit Notice, and we will note that fact in our Debit Notice to you for such Direct Debit.
   
   The Threshold Amount is currently $1,000, but we may change that at any time without notice to you. We will endeavor to notify you in writing promptly of any such change to the Threshold Amount, but our failure to so notify you will not negate any such change or result in any liability to you.
   
   We may, from time to time, add additional security measures, in our sole discretion, with or without notice to you. Such security measures may, in some instances, result in a Direct Debit being delayed or rejected. We will not be liable to you for any loss or damages you incur as a result of our delay or rejection of your Direct Debit as the result of such security measures.
   
   
   
3. Use and Purpose: For security reasons, we may limit the amount or number of transactions you can make using the Service. You may not use the Service for any illegal transaction. If we suspect that you have used the Service to conduct an illegal transaction, we reserve the right to cancel your enrollment in the Service. We reserve the right to decline any Direct Debit request at any time, even if there is sufficient Spending Power available in the Brokerage Account to settle the transaction, if, in our sole discretion, we believe that a transaction is for an improper purpose, is fraudulent, or is otherwise not within the terms of the Service as set forth by IBKR from time to time. IBKR will not be liable for any incidental or consequential damages incurred by you or any other person as a result of IBKR declining any Direct Debit request under such circumstances.
   
   
4. Available to Withdraw: Your Spending Power may fluctuate from day to day because it is dependent upon changes in the Available Cash Balance (and, in the case of margin accounts, available Margin Spending Limit) in your Brokerage Account. Promptly after IBKR is notified of a Direct Debit request, your Spending Power is reduced. You promise not to make a transaction that exceeds your Spending Power. If you attempt to make a transaction that will exceed your Spending Power, the transaction will normally be declined. If, for any reason, such transaction is not declined, you agree to be responsible for such transaction to the full extent permitted under the applicable Agreement(s).
   
   
5. Payment for Direct Debit Transactions: On a daily basis, IBKR will receive notice of the direct debit transactions you have initiated using the Service. Funds will automatically be withdrawn from your Brokerage Account to satisfy the debits that are settling that day. You authorize IBKR to charge your Brokerage Account in order to pay for transactions that you initiate through an External Account. Each transaction shall be considered to be your direction to us to charge your Brokerage Account in order to settle the Direct Debit transaction you have initiated. When you make a payment using the Service, the charge or reduction to your Spending Power generally occurs immediately upon receipt by IBKR of the Direct Debit request.
   
   
6. Payment of Items: All transactions made using the Service will be accumulated daily, and charged to your Brokerage Account in any order we may choose. We will debit your Brokerage Account in the transaction amount on the day a transaction settles, including any fees or other charges associated with the transaction. If you do not have a sufficient Available Cash Balance at the time a transaction settles, if you have a margin account, we will settle the transaction by increasing your current margin debit (if any), up to your Margin Spending Limit. If you do not have sufficient Spending Power to settle a Direct Debit request, we will decline the request. If we inadvertently approve and settle a Direct Debit for which you lack sufficient Spending Power, you hereby authorize us to attempt to reverse the transaction with the External Correspondent. If we are unable to do so, you understand that you will be liable for the full amount of the Direct Debit, even if it exceeded your Spending Power at the time of settlement.
   
   You understand that margin transactions carry substantially increased risk, including the risk that we will be obligated to liquidate your Brokerage Account in part or whole if your Brokerage Account falls below its minimum maintenance margin level, and that you will be charged interest on any margin debit you incur. You understand that IBKR generally will not issue margin calls in connection with margin deficiencies and that you may not be able to transfer funds into your Brokerage Account quickly enough to prevent liquidation in the event that your Brokerage Account falls below maintenance margin requirements on either an intraday or overnight basis. Please read the section of your Customer Agreement titled "Margin" for more details about the risks of margin trading and IBKR's policies in connection with margin deficits, margin calls, and liquidation.
   
   
7. Limitations on Frequency and Dollar Amounts of Transactions: For security reasons, we may further limit the number or dollar amount of Direct Debit transactions you can make per day, or the maximum amount of any single Direct Debit transaction, using this Service. Current limits can be found at https://www.ibkr.com.
   
   
8. Recurring Transactions: If you intend to use this Service for recurring transactions, you should monitor your balance and ensure you have funds available in your Brokerage Account to cover the transactions. "Recurring transactions" are transactions that are authorized in advance by you to be charged to your Brokerage Account at substantially regular intervals. We are not responsible if a recurring transaction is declined because you have not maintained a sufficient balance in your Brokerage Account to cover the transaction. If you have authorized an External Correspondent or merchant to make a recurring transaction and you do not expect to have sufficient Spending Power in your Brokerage Account to cover the transaction, you also should contact the applicable External Correspondent or merchant in order to stop the recurring transaction.
   
   
9. Authorization to Share Information With Third Parties: We will not reveal any information to third parties about your Brokerage Account or any transaction information in connection with your participation in this Service, EXCEPT you hereby authorize us to share information concerning your transactions: (1) with our affiliates and agents for the purpose of servicing your participation in the Service; (2) where it is necessary for completing your transactions or providing you other services; (3) to other persons and entities in order to resolve disputes arising from transactions; or (4) in any other circumstances contemplated by our Privacy Policy, as furnished to you separately and updated or amended from time to time by us.
   
   
10. Your Liability: You should tell us AT ONCE (by calling 1-866-532-4654) and submit a Written Statement of Unauthorized Debit to Interactive Brokers LLC (by mailing Interactive Brokers Direct Debit, 209 S. LaSalle Street, 10th Floor, Chicago, IL 60604 or electronically via Account Management) if you believe any unauthorized Direct Debit transactions have been made in your Brokerage Account.
    
    If you tell us within 2 Business Days after you learn of an unauthorized Direct Debit transaction and/or the loss or theft of your IBKR Mobile credentials, you can lose no more than $50 if someone initiated a Direct Debit and/or used your IBKR Mobile credentials to approve a Direct Debit without your permission. If you do NOT tell us within 2 Business Days after you learn of an unauthorized transaction and/or of the loss or theft of your IBKR Mobile credentials, and we can prove we could have stopped someone from engaging in an unauthorized Direct Debit if you had told us, you could lose as much as $500.
    
    If your statement shows Direct Debits that you did not authorize, tell us at once. If you do not tell us within 60 calendar days after the statement showing the first unauthorized transaction was made available to you, you may not get back any money you lost after the 60 days if we can prove that we could have stopped someone from taking the money if you had told us in time. If a good reason (such as a long trip or a hospital stay) kept you from telling us, we will extend the time periods.
    
    
11. Our Liability: If we do not complete a transfer to or from your Brokerage Account on time or in the correct amount according to our agreement with you, we will be liable for your losses or damages. However, there are some exceptions. We will not be liable, for instance: (1) if, through no fault of ours, you do not have enough Spending Power to make the transfer; (2) if the system was not working properly and you knew about the breakdown when you started the transfer; (3) if circumstances beyond our control (such as fire or flood) prevent the transfer, despite reasonable precautions that we have taken; (4) there may be other exceptions stated in our Agreement with you.
    
    
12. Unauthorized Transaction: In case of errors or questions about your Direct Debits, telephone us at 1-866-532-4654, or write us at Interactive Brokers LLC, ATTN: Interactive Brokers Direct Debit, 209 S. LaSalle Street, 10th Floor, Chicago, IL 60604, or log into your Brokerage Account as soon as you can. We must hear from you no later than 60 calendar days after the FIRST statement showing the error becomes available. When you contact us: (1) Tell us your name and Brokerage Account number; (2) Describe the error or the transfer you are unsure about, and explain as clearly as you can why you believe it is an error or why you need more information; (3) Tell us the dollar amount of the suspected error; (4) Fill out and sign the Written Statement of Unauthorized Debit that will be provided to you and submit it to Customer Service electronically. If you report an unauthorized transaction to us orally, we will still require you to submit a Written Statement of Unauthorized Debit (as set forth above).
    
    We will tell you the results within three Business Days after completing our investigation. If we decide that there was no error, we will send you a written explanation. You may ask for copies of the documents that we used in our investigation.
    
    
13. No Warranty: In the event that you pay a third-party, directly or indirectly, for any goods or services through the use of the Service, we are not responsible for the delivery, quality, safety, legality or any other aspect of such goods or services. Any disputes regarding any such goods or services must be addressed to the merchants from whom any such goods and services were purchased.
    
    
14. Notices: Notices and other communications relating to your Brokerage Account in connection with your use of the Service (including, without limitation, communications relating to your Spending Power) will be provided electronically in accordance with your Customer Agreement.
    
    
15. Termination of the Service: IBKR or you may terminate the Service contemplated under this Supplement at any time. You shall remain responsible for authorized charges that arise before or after termination of the Service. In the event of termination for whatever reason, you shall promptly destroy all property relating to the Service.
    
    
16. Disputes Involving Your Brokerage Account: This Supplement shall be treated for all purposes as forming a part of the Customer Agreement. Any dispute between you and IBKR, arising from any of the services contemplated by this Supplement, shall be governed by the pre-dispute mandatory arbitration provision of the Customer Agreement.

THE CUSTOMER AGREEMENT, WHICH THIS SUPPLEMENT FORMS A PART OF, CONTAINS A PRE-DISPUTE ARBITRATION CLAUSE IN PARAGRAPH 34. BY SIGNING THIS SUPPLEMENT, I ACKNOWLEDGE THAT THIS AGREEMENT CONTAINS A PRE-DISPUTE ARBITRATION CLAUSE AND THAT I HAVE RECEIVED, READ AND UNDERSTOOD THE TERMS THEREOF.

Additional Terms & Conditions for Use of Android Pay to Supplement Your Interactive Brokers Debit Mastercard Cardholder Agreement

These terms and conditions ("Terms and Conditions") are a legal agreement between you and Metropolitan Commercial Bank ("MCB," "the Bank," "our," "we" or "us") and govern your use of your Interactive Brokers Debit Mastercard through Android Pay on any payment-supported device developed or authorized by Google, Inc. ("Google") from time to time to support Android Pay ("Eligible Devices"). The term "Android Pay" means the Android Pay mobile payment functionality offered by Google and the Card provisioning functionality performed, and transaction history displayed, by the digital wallet application, on the Web, and on any other Eligible Device. In this Agreement, "Card" means the Interactive Brokers Debit Mastercard issued to you by MCB. The "Program Manager" for the Interactive Brokers Debit Mastercard is Interactive Brokers LLC ("IB"). "Card Account" means your beneficial interest in the pooled deposit account at MCB held by IB on behalf of its customers in connection with their respective Cards. Under the terms of your brokerage account with IB ("Brokerage Account") and the Interactive Brokers Debit Mastercard Cardholder Agreement ("Cardholder Agreement") with MCB, your Brokerage Account is linked to your Card Account and will automatically fund your Card Account as needed to settle transactions made with your Card; see Cardholder Agreement for full details. "You" and "your" means the person who has received the Card and who is authorized to use the Card as provided for in this Agreement. The Program Manager will determine, in its sole discretion on the Bank’s behalf, which Cards will be eligible for use through Android Pay.

Please review these Terms and Conditions before you decide whether to accept them and continue with the addition of your Card to Android Pay. You consent to the receiving of these Terms and Conditions electronically. By using a Card in Android Pay you agree to only use your Card through Android Pay in accordance with these Terms and Conditions. If you do not agree to these Terms and Conditions, then you may not add your Card to or use your Card in connection with Android Pay. These Terms and Conditions supersede any prior terms and conditions you may have agreed to with respect to access to and the use of Cards through Android Pay. You agree that these Terms and Conditions govern your access to and use of Cards through Android Pay on all Eligible Devices. Your use of Android Pay to purchase goods and services with your Card is still governed by the Cardholder Agreement between you and us, in connection with your Card, and all such terms and conditions, including the pre-dispute arbitration clause, contained in the Cardholder Agreement. The Cardholder Agreement is incorporated by reference as part of these Terms and Conditions. The arbitration provision applies to any disputes between you and us arising from your access to or use of Cards in connection with Android Pay. If any inconsistency between the two documents, this Supplement will control for the use of Android Pay.

You also acknowledge that your use of Android Pay is subject to the terms and conditions set forth by Google with respect to the use of Android Pay.

ELIGIBILITY / ENROLLMENT

Android Pay is available to you for the purposes of purchasing goods and services with an Eligible Device at merchants that accept Android Pay as a form of payment through near field communication (NFC) enabled payment terminals and for in–app purchases and authorized merchant websites when using a compatible browser. Android Pay allows you to use your Eligible Device to access and use your Card to make such purchases in place of presenting or using your physical Card and to make purchases in-app or on websites at merchants participating in Android Pay. When you select a Card to use with Android Pay, certain account information related to the Card will be transmitted to and stored within your Eligible Device or on Google’s cloud platform to facilitate your participation in Android Pay. Once the account information for a Card has been stored on your Eligible Device, it is represented by a virtual representation of your Card within Android Pay. By adding this Card to Android Pay or selecting this Card as the default card in Android Pay, unlocking and/or placing your Eligible Device near a merchant's contactless-enabled point-of-sale terminal or reader or using this Card for an in-app or website purchase, you are authorizing the payment for the merchant's products or services with that Card with Android Pay. To complete transactions above a certain dollar amount, merchants may require presentation of a physical companion card or a government-issued form of identification for inspection at the point-of-sale to authenticate your identity. You may need to present your Eligible Device at a merchant when you return an item purchased using Android Pay on such Eligible Device. You authorize your wireless operator (AT&T, Sprint, T–Mobile, US Cellular, Verizon or any other branded wireless operator) to disclose your mobile number, name, address, email, network status, customer type, customer role, billing type, account activation date, and device make and model, where provided in accordance with your mobile operator's privacy policy, to allow verification of your identity and to compare information you have provided in connection with your Card Account with your mobile operator account profile information. This disclosed data may be used and stored for fraud prevention purposes and/or to complete transactions.

YOUR USE OF YOUR CARD THROUGH ANDROID PAY

Please review the Cardholder Agreement, as applicable, for important information on your rights and responsibilities when making purchases. If your Eligible Device is lost or stolen, your fingerprint identity or passcode is compromised or Card has been used through Android Pay without your permission, you must notify the Program Manager, as agent for MCB, immediately using the number provided on the back of your Card or by logging into your Brokerage Account at www.IBKR.com. If you fail to notify us without delay, you may be liable for part or all of the losses in connection with any unauthorized use of your Card in connection with Android Pay. Refer to your Cardholder Agreement for information regarding your liability for unauthorized transfers.

You agree and acknowledge that the transaction history displayed in Android Pay, in connection with use of your Card in Android Pay, solely represents our authorization of your Android Pay transaction and does not reflect any post–authorization activity including, but not limited to, clearing, settlement, foreign currency exchange, reversals, returns or chargebacks. Accordingly, the purchase amount, currency and other details for your Android Pay transaction history in connection with use of your Card in Android Pay may not match the transaction amount that ultimately clears, settles and posts to your Card Account. We do not impose a fee for using your Card through Android Pay. Your telecommunications carrier or provider or Google may impose web–enablement, data usage or text messaging fees or other charges for your use of Android Pay.

AUTHORIZATION TO COLLECT AND SHARE DATA

You agree that we may collect, transmit, store, and use technical, location, and login or other information about you and your use of the Cards through Android Pay. You acknowledge that (i) Google, the provider of Android Pay technology that supports the Cards in Android Pay, as well as Google's sub–contractors, agents, and affiliates, and (ii) the applicable payment network branded on your Card (e.g., MasterCard International Incorporated and its affiliate Maestro, American Express, or Visa U.S.A. Inc. and its affiliate Interlink) as well as such network's sub–contractors, agents, and affiliates, will have access to certain details of your transactions made with merchants via use of your Cards through Android Pay. We will use, share and protect your personal information in accordance with our Privacy Policy applicable to your Card account. A copy of our Privacy Policy is available for review in your Cardholder Agreement. You acknowledge that the use and disclosure of any personal information provided by you directly to Google, the applicable payment network branded on your Card or other third parties supporting Android Pay will be governed by such party's privacy policy and not MCB’s Privacy Policy.
COMMUNICATION

You consent to receive certain messages on your Eligible Device from the Program Manager in connection with your use of your Card through Android Pay. You may receive push notifications from time to time reflecting your Card activity. If you do not wish to receive notifications, you may turn off these notifications through the device Settings on your Eligible Device. You agree to receive notices and other communications by e-mail to the e-mail address on file for your Brokerage Account. Also, you agree to receive notices and communications through the "Message Center" for your Brokerage Account at www.ibkr.com, or through the messaging capabilities of Android Pay. To update the contact information on file for you, please log on to your Brokerage Account at www.ibkr.com.

MERCHANT RELATIONSHIPS AND DISCLAIMERS

Merchants may present to you certain discounts, rebates or other benefits (e.g. free shipping) ("Offers") in Android Pay. Such Offers are subject to certain terms and conditions and may change at any time without notice to you. Neither IB nor MCB will be liable for any loss or damage as a result of any interaction between you and a merchant with respect to such Offers. Subject to applicable law and your Cardholder Agreement, all matters, including delivery of goods and services, returns, and warranties, are solely between you and the applicable merchants. You acknowledge that we do not endorse or warrant the merchants that are accessible through Android Pay or the Offers that they provide.

CHANGES TO PARTICIPATION IN ANDROID PAY AND TERMS AND CONDITIONS

Subject to applicable law, and as provided in the Cardholder Agreement, at any time we may (i) terminate your use of a Card in connection with Android Pay, (ii) modify or suspend the type or dollar amounts of transactions allowed using your Card in connection with Android Pay, (iii) change a Card's eligibility for use with Android Pay and (iv) change the Card’s authentication process.

We may amend or change these Terms and Conditions at any time without prior notice to you except as required by applicable law. You will be notified of any change in the manner provided by applicable law prior to the effective date of the change. You are bound by such revisions and should therefore review the current Terms and Conditions as posted on the Program Manager’s website at www.ibkr.com from time to time.

INTELLECTUAL PROPERTY

All intellectual property rights including all patents, trade secrets, copyrights, trademarks and moral rights ("Intellectual Property Rights") in Android Pay (including text, graphics, software, photographs and other images, videos, sound, trademarks and logos) are owned either by Google, IB, MCB, their licensors or third parties. Nothing in these Terms and Conditions gives you any rights in respect of any intellectual property owned by Google, IB, MCB, their licensors or third parties and you acknowledge that you do not acquire any ownership rights by adding your Card to or using your Card in connection with Android Pay.

DISCLAIMERS OF WARRANTY

Android Pay is provided by Google without any warranty from IB or MCB. You acknowledge and agree that from time to time, your use of your Card in connection with Android Pay may be delayed, interrupted or disrupted for an unknown period of time for reasons we cannot control. Neither IB, MCB, nor their affiliates, agents, directors or officers will be liable for any claim arising from or related to use of your Card through Android Pay due to such delay, interruption, disruption or similar failure.

You acknowledge that we are not party to the terms and conditions for Android Pay between you and Google and we do not own and are not responsible for Android Pay. We are not providing any warranty for Android Pay. We are not responsible for maintenance or other support services for Android Pay and shall not be responsible for any other claims, losses, liabilities, damages, costs or expenses with respect to Android Pay, including, without limitation, any third-party product liability claims, claims that Android Pay fails to conform to any applicable legal or regulatory requirement, claims arising under consumer protection or similar legislation, and claims with respect to intellectual property infringement. Any inquiries or complaints relating to the use of Android Pay, including those pertaining to Intellectual Property Rights, must be directed to Google.

We do not recommend, endorse or make any representation or warranty of any kind regarding the performance or operation of your Eligible Device. You are responsible for the selection of an Eligible Device and for all issues relating to the operation, performance and costs associated with such Eligible Device.

LIMITATION OF LIABILITY

TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, IN NO EVENT SHALL WE, OUR PROGRAM MANAGER, PROCESSORS, SUPPLIERS, OR LICENSORS (OR THEIR RESPECTIVE AFFILIATES, AGENTS, DIRECTORS AND EMPLOYEES) BE LIABLE FOR ANY DIRECT, INDIRECT, PUNITIVE, INCIDENTAL, SPECIAL, CONSEQUENTIAL OR EXEMPLARY DAMAGES, INCLUDING WITHOUT LIMITATION DAMAGES FOR LOSS OF PROFITS, GOODWILL, USE, DATA OR OTHER INTANGIBLE LOSSES, THAT RESULT FROM THE USE OF, INABILITY TO USE OR UNAVAILABILITY OF ANDROID PAY, INCLUDING YOUR USE OF YOUR CARD IN CONNECTION WITH ANDROID PAY. UNDER NO CIRCUMSTANCES WILL WE BE RESPONSIBLE FOR ANY DAMAGE, LOSS OR INJURY RESULTING FROM HACKING, TAMPERING OR OTHER UNAUTHORIZED ACCESS OR USE OF YOUR CARD IN ANDROID PAY.

TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, WE, OUR PROGRAM MANAGER, PROCESSORS, SUPPLIERS AND LICENSORS (AND THEIR RESPECTIVE AFFILIATES, AGENTS, DIRECTORS AND EMPLOYEES) ASSUME NO LIABILITY OR RESPONSIBILITY FOR ANY (I) ERRORS, MISTAKES OR INACCURACIES OF CONTENT; (II) PERSONAL INJURY OR PROPERTY DAMAGE, OF ANY NATURE WHATSOEVER, RESULTING FROM YOUR ACCESS TO OR USE OF ANDROID PAY, INCLUDING YOUR USE OF YOUR CARD IN CONNECTION WITH ANDROID PAY; (III) ANY UNAUTHORIZED ACCESS TO OR USE OF OUR SECURE SERVERS AND/OR ANY AND ALL PERSONAL INFORMATION STORED THEREIN; (IV) ANY INTERRUPTION OR CESSATION OF TRANSMISSION TO OR FROM ANDROID PAY; (V) ANY BUGS, VIRUSES, TROJAN HORSES OR THE LIKE THAT MAY BE TRANSMITTED TO OR THROUGH ANDROID PAY BY ANY THIRD PARTY; (VI) ANY ERRORS OR OMISSIONS IN ANY CONTENT OR FOR ANY LOSS OR DAMAGE INCURRED AS A RESULT OF THE USE OF ANY CONTENT POSTED, EMAILED, TRANSMITTED OR OTHERWISE MADE AVAILABLE THROUGH ANDROID PAY; AND/OR (VII) USER CONTENT OR THE DEFAMATORY, OFFENSIVE OR ILLEGAL CONDUCT OF ANY THIRD PARTY. IN NO EVENT SHALL WE, OUR PROGRAM MANAGER, PROCESSORS, AGENTS, SUPPLIERS OR LICENSORS (OR THEIR RESPECTIVE AFFILIATES, AGENTS, DIRECTORS AND EMPLOYEES) BE LIABLE TO YOU FOR ANY CLAIMS, PROCEEDINGS, LIABILITIES, OBLIGATIONS, DAMAGES, LOSSES OR COSTS IN AN AMOUNT EXCEEDING $500.

THIS LIMITATION OF LIABILITY SECTION APPLIES WHETHER THE ALLEGED LIABILITY IS BASED ON CONTRACT, TORT, NEGLIGENCE, STRICT LIABILITY OR ANY OTHER BASIS, EVEN IF WE HAVE BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGE. THE FOREGOING LIMITATION OF LIABILITY SHALL APPLY TO THE FULLEST EXTENT PERMITTED BY LAW IN THE APPLICABLE JURISDICTION.

INDEMNITY

You agree to indemnify, defend and hold us and the Program Manager harmless (and the employees, directors, agents, affiliates and representatives of each) from and against any and all claims, costs, losses, damages, judgments, tax assessments, penalties, interest and expenses (including reasonable attorneys' fees) arising out of any claim, action, audit, investigation, inquiry or other proceeding instituted by a person or entity that arises out of or relates to: (a) any actual or alleged breach of your representations, warranties or obligations set forth in this Terms and Conditions, including any violation of our policies; (b) your wrongful or improper use of Android Pay, including willful misconduct or fraud; (c) your violation of any third–party right, including without limitation any right of privacy, publicity rights or Intellectual Property Rights; (d) your violation of any law, rule or regulation of the United States or any other country; (e) any other party's access or use of Android Pay with your fingerprint identity or other appropriate security code.

REPRESENTATION AND WARRANTY

You represent and warrant to us that: (i) to the extent you identified a name at registration, the name identified by you when you registered your Card to be added to Android Pay is your name; (ii) the Card you added to Android Pay is your Card; (iii) you have the authority to authorize the receipt of notices, emails, calls and text messages from MCB or Program Manager at the phone number or email address you provide; (iv) you and all transactions initiated by you will comply with all federal, state, and local laws, rules, and regulations applicable to you, including any applicable tax laws and regulations; (v) you will not use your Card through Android Pay for any fraudulent or illegal undertaking or in any manner so as to interfere with the operation of Android Pay; and (vi) your use of your Card in connection with Android Pay will comply with these Terms and Conditions.

GOVERNING LAW

These Terms and Conditions, your use of your Card through Android Pay, and any claim, dispute or controversy arising from or relating to these Terms and Conditions shall be governed by the law of the State of New York, without giving effect to the conflict of law principles thereof, except to the extent preempted or governed by federal law. The legality, enforceability and interpretation of these Terms and Conditions and the amounts contracted for, charged and received under these Terms and Conditions, if any, will be governed by such laws. These Terms and Conditions are entered into between you and us in New York. Subject to the arbitration provision in the Cardholder Agreement, you expressly agree that exclusive jurisdiction for any claim or dispute with us or relating in any way to these Terms and Conditions or your use of your Card resides in the state and federal courts located in New York County, New York and you further agree and expressly consent to the exercise of personal jurisdiction in such courts in connection with any such dispute including any claim involving us or our affiliates, subsidiaries, employees, contractors, officers, directors, agents and content providers.

Additional Terms & Conditions for Use of Apple Pay to Supplement Your Interactive Brokers Debit Mastercard Cardholder Agreement

These terms and conditions ("Terms and Conditions") are a legal agreement between you and Metropolitan Commercial Bank ("MCB," "the Bank," "our," "we," or "us") and govern your use of your Interactive Brokers Debit Mastercard in connection with Apple Pay (as defined below) on payment-supported iOS devices determined and commercialized by Apple from time to time ("Eligible Devices"). The term "Apple Pay" shall include the Apple Pay branded payment functionality and the Card provisioning functionality performed, and transaction history displayed, by the Wallet application, the Apple Watch application, Apple Pay on the Web, the Apple Watch, and on any other Eligible Device. In this Agreement, "Card" means the Interactive Brokers Debit Mastercard issued to you by MCB. The "Program Manager" for the Interactive Broker Debit Mastercard is Interactive Brokers LLC ("IB"). "Card Account" means your beneficial interest in the pooled deposit account at MCB held by IB on behalf of its customers in connection with their respective Cards. Under the terms of your brokerage account with IB ("Brokerage Account") and the Interactive Brokers Debit Mastercard Cardholder Agreement ("Cardholder Agreement") with MCB, your Brokerage Account is linked to your Card Account and will automatically fund your Card Account as needed to settle transactions made with your Card; see Cardholder Agreement for full details. "You" and "your" means the person who has received the Card and who is authorized to use the Card as provided for in this Agreement. The term "Program Manager" will refer to Interactive Brokers LLC ("IB"). The Program Manager will determine, in its sole discretion on the Bank’s behalf, which Cards will be eligible for use through Apple Pay.

Please review these Terms and Conditions before you decide whether to accept them and continue with the addition of your Card to Apple Pay. You consent to the receiving of these Terms and Conditions electronically. By using a Card in Apple Pay you agree to only use your Card through Apple Pay in accordance with these Terms and Conditions. If you do not agree to these Terms and Conditions, then you may not add your Card to or use your Card in connection with Apple Pay. These Terms and Conditions supersede any prior terms and conditions you may have agreed to with respect to access to and the use of Cards through Apple Pay. You agree that these Terms and Conditions govern your access to and use of Cards through Apple Pay on all Eligible Devices. Your use of Apple Pay to purchase goods and services with your Card is still governed by the Cardholder Agreement between you and us in connection with your Card and all such terms and conditions, including the pre-disputes arbitration clause, contained in the Cardholder Agreement. The Cardholder Agreement is incorporated by reference as part of these Terms and Conditions. The arbitration provision applies to any disputes between you and us arising from your access to or use of Cards in connection with Apple Pay. I any inconsistency between the two documents, this Supplement will control for the use of Android Pay.

You also acknowledge that your use of Apple Pay is subject to the terms and conditions set forth by Apple, Inc. ("Apple") with respect to the use of Apple Pay.

ELIGIBILITY / ENROLLMENT

Apple Pay is available to you for the purposes of purchasing goods and services with an Eligible Device at merchants that accept Apple Pay as a form of payment through near field communication (NFC) enabled payment terminals, for in–app purchases and authorized merchant websites when using a compatible Safari browser on a compatible MacBook Pro. Apple Pay allows you to use your Eligible Device to access and use your Cards to make such purchases in place of presenting or using your physical Card. To add your Card to Apple Pay, you must register your Card with Apple Pay by linking ("provisioning") your Card to an Eligible Device. You may be required to take additional steps to authenticate yourself before your Card is added to Apple Pay, which may include providing additional identifying information. When provisioning your Card through Apple Pay to an Eligible Device that contains a secure element, a unique numerical identifier different from your Card number ("Token") will be added to such secure element, for the purpose of making purchases through Apple Pay. If your physical plastic Card is lost or stolen, but your Eligible Device is not lost or stolen, upon provisioning your new physical plastic Card to Apple Pay, Apple Pay will automatically assign your new physical plastic Card to your existing Token. Due to the manner in which Apple Pay operates, you may need to present your Eligible Device at a merchant when you return an item purchased using Apple Pay on such Eligible Device. You authorize your wireless operator (AT&T, Sprint, T–Mobile, US Cellular, Verizon, or any other branded wireless operator) to disclose your mobile number, name, address, email, network status, customer type, customer role, billing type, account activation date, and device make and model, where provided in accordance with your mobile operator's privacy policy, to allow verification of your identity and to compare information you have provided in connection with your Card Account with your mobile operator account profile information. This disclosed data may be used and stored for fraud prevention purposes and/or to complete transactions.

YOUR USE OF YOUR CARD THROUGH APPLE PAY

Please review the Cardholder Agreement, as applicable, for important information on your rights and responsibilities when making purchases. If your Eligible Device is lost or stolen, your Touch ID (fingerprint identity) or other passcode is compromised or Card has been used through Apple Pay without your permission, you must notify the Program Manager, as agent for MCB, immediately using the number provided on the back of your Card or by logging into your Brokerage Account at www.IBKR.com. If you fail to notify us without delay, you may be liable for part or all of the losses in connection with any unauthorized use of your Card in connection with Apple Pay. Refer to your Cardholder Agreement for information regarding your liability for unauthorized transfers.

You agree and acknowledge that the transaction history displayed in Apple Pay in connection with use of your Card in Apple Pay solely represents our authorization of your Apple Pay transaction and does not reflect any post–authorization activity including, but not limited to, clearing, settlement, foreign currency exchange, reversals, returns or chargebacks. Accordingly, the purchase amount, currency, and other details for your Apple Pay transaction history in connection with use of your Card in Apple Pay may not match the transaction amount that ultimately clears, settles, and posts to your Card Account. We do not impose a fee for using your Card through Apple Pay. Your telecommunications carrier or provider or Apple may impose web–enablement, data usage or text messaging fees or other charges for your use of Apple Pay.
Devices modified contrary to the manufacturer's software or hardware guidelines, including by disabling hardware or software controls–sometimes referred to as "jailbreaking"–are not Eligible Devices. You acknowledge that the use of a modified device to use your Card in connection with Apple Pay is expressly prohibited, constitutes a violation of the Terms & Conditions, and is grounds for us to deny your access to your Card through Apple Pay. You acknowledge that in some instances your Eligible Device can be used to make purchases using Apple Pay without waking the Eligible Device.

AUTHORIZATION TO COLLECT AND SHARE DATA

You agree that we may collect, transmit, store, and use technical, location, and login or other information about you and your use of the Cards through Apple Pay. You acknowledge that (i) Apple, the provider of Apple Pay technology that supports the Cards in Apple Pay, as well as Apple's sub–contractors, agents, and affiliates, and (ii) the applicable payment network branded on your Card (e.g., MasterCard International Incorporated and its affiliate Maestro, American Express, or Visa U.S.A. Inc. and its affiliate Interlink) as well as such network's sub–contractors, agents, and affiliates, will have access to certain details of your transactions made with merchants via use of your Cards through Apple Pay. We will use, share and protect your personal information in accordance with our Privacy Policy applicable to your Card account. A copy of our Privacy Policy is available for review in your Cardholder Agreement. You acknowledge that the use and disclosure of any personal information provided by you directly to Apple, the applicable payment network branded on your Card or other third parties supporting Apple Pay will be governed by such party's privacy policy and not MCB’s Privacy Policy.

COMMUNICATION

You consent to receive certain messages on your Eligible Device from the Program Manager in connection with your use of your Card through Apple Pay. You may receive push notifications from time to time reflecting your Card activity. If you do not wish to receive notifications, you may turn off these notifications through the device Settings on your Eligible Device. You agree to receive notices and other communications by e-mail to the e-mail address on file for your Brokerage Account. Also, you agree to receive notices and communications through the "Message Center" for your Brokerage Account at www.ibkr.com, or through the messaging capabilities of Apple Pay. To update the contact information on file for you, please log on to your Brokerage Account at www.ibkr.com.

MERCHANT RELATIONSHIPS AND DISCLAIMERS

Merchants may present to you certain discounts, rebates or other benefits (e.g. free shipping) ("Offers") in Apple Pay. Such Offers are subject to certain terms and conditions and may change at any time without notice to you. Neither IB nor MCB will be liable for any loss or damage as a result of any interaction between you and a merchant with respect to such Offers. Subject to applicable law and your Cardholder Agreement, all matters, including delivery of goods and services, returns, and warranties, are solely between you and the applicable merchants. You acknowledge that we do not endorse or warrant the merchants that are accessible through Apple Pay or the Offers that they provide.

CHANGES TO PARTICIPATION IN APPLE PAY AND TERMS AND CONDITIONS

Subject to applicable law, and as provided in the Cardholder Agreement, at any time we may (i) terminate your use of a Card in connection with Apple Pay, (ii) modify or suspend the type or dollar amounts of transactions allowed using your Card in connection with Apple Pay, (iii) change a Card's eligibility for use with Apple Pay and (iv) change the Card’s authentication process.

We may amend or change these Terms and Conditions at any time without prior notice to you except as required by applicable law. You will be notified of any change in the manner provided by applicable law prior to the effective date of the change. You are bound by such revisions and should therefore review the current Terms and Conditions as posted on the Program Manager’s website at www.ibkr.com from time to time.

INTELLECTUAL PROPERTY

All intellectual property rights including all patents, trade secrets, copyrights, trademarks and moral rights ("Intellectual Property Rights") in Apple Pay (including text, graphics, software, photographs and other images, videos, sound, trademarks and logos) are owned either by Apple, IB, MCB, their licensors or third parties. Nothing in these Terms and Conditions gives you any rights in respect of any intellectual property owned by Apple, IB, MCB, their licensors or third parties and you acknowledge that you do not acquire any ownership rights by adding your Card to, or using your Card in connection with Apple Pay.

DISCLAIMERS OF WARRANTY

Apple Pay is provided by Apple without any warranty from IB or MCB. You acknowledge and agree that from time to time, your use of your Card in connection with Apple Pay may be delayed, interrupted or disrupted for an unknown period of time for reasons we cannot control. Neither IB, MCB, nor their affiliates, agents, directors or officers will be liable for any claim arising from or related to use of your Card through Apple Pay due to such delay, interruption, disruption or similar failure.

You acknowledge that we are not party to the terms and conditions for Apple Pay between you and Apple and we do not own and are not responsible for Apple Pay. We are not providing any warranty for Apple Pay. We are not responsible for maintenance or other support services for Apple Pay and shall not be responsible for any other claims, losses, liabilities, damages, costs or expenses with respect to Apple Pay, including, without limitation, any third-party product liability claims, claims that Apple Pay fails to conform to any applicable legal or regulatory requirement, claims arising under consumer protection or similar legislation, and claims with respect to intellectual property infringement. Any inquiries or complaints relating to the use of Apple Pay, including those pertaining to Intellectual Property Rights, must be directed to Apple.

We do not recommend, endorse or make any representation or warranty of any kind regarding the performance or operation of your Eligible Device. You are responsible for the selection of an Eligible Device and for all issues relating to the operation, performance and costs associated with such Eligible Device.

LIMITATION OF LIABILITY

TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, IN NO EVENT SHALL WE, OUR PROGRAM MANAGER, PROCESSORS, SUPPLIERS OR LICENSORS (OR THEIR RESPECTIVE AFFILIATES, AGENTS, DIRECTORS AND EMPLOYEES) BE LIABLE FOR ANY DIRECT, INDIRECT, PUNITIVE, INCIDENTAL, SPECIAL, CONSEQUENTIAL OR EXEMPLARY DAMAGES, INCLUDING WITHOUT LIMITATION DAMAGES FOR LOSS OF PROFITS, GOODWILL, USE, DATA OR OTHER INTANGIBLE LOSSES, THAT RESULT FROM THE USE OF, INABILITY TO USE OR UNAVAILABILITY OF APPLE PAY, INCLUDING YOUR USE OF YOUR CARD IN CONNECTION WITH APPLE PAY. UNDER NO CIRCUMSTANCES WILL WE BE RESPONSIBLE FOR ANY DAMAGE, LOSS OR INJURY RESULTING FROM HACKING, TAMPERING OR OTHER UNAUTHORIZED ACCESS OR USE OF YOUR CARD IN APPLE PAY.

TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, WE, OUR PROGRAM MANAGER, PROCESSORS, SUPPLIERS AND LICENSORS (AND THEIR RESPECTIVE AFFILIATES, AGENTS, DIRECTORS AND EMPLOYEES) ASSUME NO LIABILITY OR RESPONSIBILITY FOR ANY (I) ERRORS, MISTAKES OR INACCURACIES OF CONTENT; (II) PERSONAL INJURY OR PROPERTY DAMAGE, OF ANY NATURE WHATSOEVER, RESULTING FROM YOUR ACCESS TO OR USE OF APPLE PAY, INCLUDING YOUR USE OF YOUR CARD IN CONNECTION WITH APPLE PAY; (III) ANY UNAUTHORIZED ACCESS TO OR USE OF OUR SECURE SERVERS AND/OR ANY AND ALL PERSONAL INFORMATION STORED THEREIN; (IV) ANY INTERRUPTION OR CESSATION OF TRANSMISSION TO OR FROM APPLE PAY; (V) ANY BUGS, VIRUSES, TROJAN HORSES OR THE LIKE THAT MAY BE TRANSMITTED TO OR THROUGH APPLE PAY BY ANY THIRD PARTY; (VI) ANY ERRORS OR OMISSIONS IN ANY CONTENT OR FOR ANY LOSS OR DAMAGE INCURRED AS A RESULT OF THE USE OF ANY CONTENT POSTED, EMAILED, TRANSMITTED OR OTHERWISE MADE AVAILABLE THROUGH APPLE PAY; AND/OR (VII) USER CONTENT OR THE DEFAMATORY, OFFENSIVE OR ILLEGAL CONDUCT OF ANY THIRD PARTY. IN NO EVENT SHALL WE, OUR PROGRAM MANAGER, PROCESSORS, AGENTS, SUPPLIERS OR LICENSORS (OR THEIR RESPECTIVE AFFILIATES, AGENTS, DIRECTORS AND EMPLOYEES) BE LIABLE TO YOU FOR ANY CLAIMS, PROCEEDINGS, LIABILITIES, OBLIGATIONS, DAMAGES, LOSSES OR COSTS IN AN AMOUNT EXCEEDING $500.

THIS LIMITATION OF LIABILITY SECTION APPLIES WHETHER THE ALLEGED LIABILITY IS BASED ON CONTRACT, TORT, NEGLIGENCE, STRICT LIABILITY OR ANY OTHER BASIS, EVEN IF WE HAVE BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGE. THE FOREGOING LIMITATION OF LIABILITY SHALL APPLY TO THE FULLEST EXTENT PERMITTED BY LAW IN THE APPLICABLE JURISDICTION.

INDEMNITY

You agree to indemnify, defend and hold us and the Program Manager harmless (and the employees, directors, agents, affiliates and representatives of each) from and against any and all claims, costs, losses, damages, judgments, tax assessments, penalties, interest and expenses (including reasonable attorneys' fees) arising out of any claim, action, audit, investigation, inquiry or other proceeding instituted by a person or entity that arises out of or relates to: (a) any actual or alleged breach of your representations, warranties, or obligations set forth in this Terms and Conditions, including any violation of our policies; (b) your wrongful or improper use of Apple Pay, including willful misconduct or fraud; (c) your violation of any third–party right, including without limitation any right of privacy, publicity rights or Intellectual Property Rights; (d) your violation of any law, rule or regulation of the United States or any other country; (e) any other party's access or use of Apple Pay with your Touch ID or other appropriate security code.

REPRESENTATION AND WARRANTY

You represent and warrant to us that: (i) to the extent you identified a name at registration, the name identified by you when you registered your Card to be added to Apple Pay is your name; (ii) the Card you added to Apple Pay is your Card; (iii) you have the authority to authorize the receipt of notices, emails, calls and text messages from MCB or Program Manager at the phone number or email address you provide; (iv) you and all transactions initiated by you will comply with all federal, state and local laws, rules, and regulations applicable to you, including any applicable tax laws and regulations; (v) you will not use your Card through Apple Pay for any fraudulent or illegal undertaking or in any manner so as to interfere with the operation of Apple Pay; and (vi) your use of your Card in connection with Apple Pay will comply with these Terms and Conditions.

GOVERNING LAW

These Terms and Conditions, your use of your Card through Apple Pay, and any claim, dispute or controversy arising from or relating to these Terms and Conditions shall be governed by the law of the State of New York, without giving effect to the conflict of law principles thereof, except to the extent preempted or governed by federal law. The legality, enforceability and interpretation of these Terms and Conditions and the amounts contracted for, charged and received under these Terms and Conditions, if any, will be governed by such laws. These Terms and Conditions are entered into between you and us in New York. Subject to the arbitration provision in the Cardholder Agreement, you expressly agree that exclusive jurisdiction for any claim or dispute with us or relating in any way to these Terms and Conditions or your use of your Card resides in the state and federal courts located in New York County, New York and you further agree and expressly consent to the exercise of personal jurisdiction in such courts in connection with any such dispute including any claim involving us or our affiliates, subsidiaries, employees, contractors, officers, directors, agents and content providers.

Additional Terms & Conditions for Use of Samsung Pay to Supplement Your Interactive Brokers Debit Mastercard Cardholder Agreement

These terms and conditions ("Terms and Conditions") are a legal agreement between you and Metropolitan Commercial Bank ("MCB," "the Bank," "our," "we" or "us") and govern your use of your Interactive Brokers Debit Mastercard through Samsung Pay on any payment-supported device developed or authorized by Samsung Electronics Co., Ltd. ("Samsung") from time to time to support Samsung Pay ("Eligible Devices"). The term "Samsung Pay" means the Samsung Pay mobile payment functionality offered by Samsung and the Card provisioning functionality performed, and transaction history displayed, by the digital wallet application, on the Web, and on any other Eligible Device. In this Agreement, "Card" means the Interactive Brokers Debit Mastercard issued to you by MCB. "Program Manager" for the Interactive Brokers Debit Mastercard is Interactive Brokers LLC ("IB"). "Card Account" means your beneficial interest in the pooled deposit account at MCB held by IB on behalf of its customers in connection with their respective Cards. Under the terms of your brokerage account with IB ("Brokerage Account") and the Interactive Brokers Debit Mastercard Cardholder Agreement ("Cardholder Agreement") with MCB, your Brokerage Account is linked to your Card Account and will automatically fund your Card Account as needed to settle transactions made with your Card, see Cardholder Agreement for full details. "You" and "your" means the person who has received the Card and who is authorized to use the Card as provided for in this Agreement. The Program Manager will determine, in its sole discretion on the Bank�s behalf, which Cards will be eligible for use through Samsung Pay.

Please review these Terms and Conditions before you decide whether to accept them and continue with the addition of your Card to Samsung Pay. You consent to the receiving of these Terms and Conditions electronically. By using a Card in Samsung Pay you agree to only use your Card through Samsung Pay in accordance with these Terms and Conditions. If you do not agree to these Terms and Conditions, then you may not add your Card to, or use your Card in connection with, Samsung Pay. These Terms and Conditions supersede any prior terms and conditions you may have agreed to with respect to access to and the use of Cards through Samsung Pay. You agree that these Terms and Conditions govern your access to and use of Cards through Samsung Pay on all Eligible Devices. Your use of Samsung Pay to purchase goods and services with your Card is still governed by the Cardholder Agreement between you and us in connection with your Card and all such terms and conditions, including the pre-dispute arbitration clause, contained in the Cardholder Agreement. The Cardholder Agreement is incorporated by reference as part of these Terms and Conditions. The arbitration provision applies to any disputes between you and us arising from your access to or use of Cards in connection with Samsung Pay. If any inconsistency between the two documents, this Supplement will control for the use of Samsung Pay.

You also acknowledge that your use of Samsung Pay is subject to the terms and conditions set forth by Samsung with respect to the use of Samsung Pay.

ELIGIBILITY / ENROLLMENT

Samsung Pay is available to you for the purposes of purchasing goods and services with an Eligible Device at merchants that accept Samsung Pay as a form of payment through near field communication (NFC) enabled payment terminals and for in–app purchases and authorized merchant websites when using a compatible browser. Samsung Pay allows you to use your Eligible Device to access and use your Card to make such purchases in place of presenting or using your physical Card and to make purchases in-app or on websites at merchants participating in Samsung Pay. When you select a Card to use with Samsung Pay, certain account information related to the Card will be transmitted to and stored within your Eligible Device or on Samsung’s cloud platform to facilitate your participation in Samsung Pay. Once the account information for a Card has been stored on your Eligible Device, it is represented by a virtual representation of your Card within Samsung Pay. By adding this Card to Samsung Pay or selecting this Card as the default card in Samsung Pay, unlocking and/or placing your Eligible Device near a merchant's contactless-enabled point-of-sale terminal or reader or using this Card for an in-app or website purchase, you are authorizing the payment for the merchant's products or services with that Card with Samsung Pay. To complete transactions above a certain dollar amount, merchants may require presentation of a physical companion card or a government-issued form of identification for inspection at the point-of-sale to authenticate your identity. You may need to present your Eligible Device at a merchant when you return an item purchased using Samsung Pay on such Eligible Device. You authorize your wireless operator (AT&T, Sprint, T–Mobile, US Cellular, Verizon, or any other branded wireless operator) to disclose your mobile number, name, address, email, network status, customer type, customer role, billing type, account activation date, and device make and model, where provided in accordance with your mobile operator's privacy policy, to allow verification of your identity and to compare information you have provided in connection with your Card Account with your mobile operator account profile information. This disclosed data may be used and stored for fraud prevention purposes and/or to complete transactions.

YOUR USE OF YOUR CARD THROUGH SAMSUNG PAY

Please review the Cardholder Agreement, as applicable, for important information on your rights and responsibilities when making purchases. If your Eligible Device is lost or stolen, your fingerprint identity or passcode is compromised or Card has been used through Samsung Pay without your permission, you must notify the Program Manager, as agent for MCB, immediately using the number provided on the back of your Card or by logging into your Brokerage Account at www.IBKR.com. If you fail to notify us without delay, you may be liable for part or all of the losses in connection with any unauthorized use of your Card in connection with Samsung Pay. Refer to your Cardholder Agreement for information regarding your liability for unauthorized transfers.

You agree and acknowledge that the transaction history displayed in Samsung Pay, in connection with use of your Card in Samsung Pay, solely represents our authorization of your Samsung Pay transaction and does not reflect any post–authorization activity including, but not limited to, clearing, settlement, foreign currency exchange, reversals, returns or chargebacks. Accordingly, the purchase amount, currency and other details for your Samsung Pay transaction history in connection with use of your Card in Samsung Pay may not match the transaction amount that ultimately clears, settles and posts to your Card Account. We do not impose a fee for using your Card through Samsung Pay. Your telecommunications carrier or provider or Samsung may impose web–enablement, data usage or text messaging fees or other charges for your use of Samsung Pay.

AUTHORIZATION TO COLLECT AND SHARE DATA

You agree that we may collect, transmit, store, and use technical, location, and login or other information about you and your use of the Cards through Samsung Pay. You acknowledge that (i) Samsung, the provider of Samsung Pay technology that supports the Cards in Samsung Pay, as well as Samsung's sub–contractors, agents, and affiliates, and (ii) the applicable payment network branded on your Card (e.g., MasterCard International Incorporated and its affiliate Maestro, American Express, or Visa U.S.A. Inc. and its affiliate Interlink) as well as such network's sub–contractors, agents, and affiliates, will have access to certain details of your transactions made with merchants via use of your Cards through Samsung Pay. We will use, share and protect your personal information in accordance with our Privacy Policy applicable to your Card account. A copy of our Privacy Policy is available for review in your Cardholder Agreement. You acknowledge that the use and disclosure of any personal information provided by you directly to Samsung, the applicable payment network branded on your Card, or other third parties supporting Samsung Pay, will be governed by such party's privacy policy and not MCB’s Privacy Policy.

COMMUNICATION

You consent to receive certain messages on your Eligible Device from the Program Manager in connection with your use of your Card through Samsung Pay. You may receive push notifications from time to time reflecting your Card activity. If you do not wish to receive notifications, you may turn off these notifications through the device Settings on your Eligible Device. You agree to receive notices and other communications by e-mail to the e-mail address on file for your Brokerage Account. Also, you agree to receive notices and communications through the “Message Center” for your Brokerage Account at www.ibkr.com, or through the messaging capabilities of Samsung Pay. To update the contact information on file for you, please log on to your Brokerage Account at www.ibkr.com.

MERCHANT RELATIONSHIPS AND DISCLAIMERS

Merchants may present to you certain discounts, rebates or other benefits (e.g. free shipping) (“Offers”) in Samsung Pay. Such Offers are subject to certain terms and conditions and may change at any time without notice to you. Neither IB nor MCB will be liable for any loss or damage as a result of any interaction between you and a merchant with respect to such Offers. Subject to applicable law and your Cardholder Agreement, all matters, including delivery of goods and services, returns, and warranties, are solely between you and the applicable merchants. You acknowledge that we do not endorse or warrant the merchants that are accessible through Samsung Pay or the Offers that they provide.

CHANGES TO PARTICIPATION IN SAMSUNG PAY AND TERMS AND CONDITIONS

Subject to applicable law, and as provided in the Cardholder Agreement, at any time we may (i) terminate your use of a Card in connection with Samsung Pay, (ii) modify or suspend the type or dollar amounts of transactions allowed using your Card in connection with Samsung Pay, (iii) change a Card's eligibility for use with Samsung Pay and (iv) change the Card’s authentication process.

We may amend or change these Terms and Conditions at any time without prior notice to you except as required by applicable law. You will be notified of any change in the manner provided by applicable law prior to the effective date of the change. You are bound by such revisions and should therefore review the current Terms and Conditions as posted on the Program Manager’s website at www.ibkr.com from time to time.

INTELLECTUAL PROPERTY

All intellectual property rights including all patents, trade secrets, copyrights, trademarks and moral rights (“Intellectual Property Rights”) in Samsung Pay (including text, graphics, software, photographs and other images, videos, sound, trademarks and logos) are owned either by Samsung, IB, MCB, their licensors or third parties. Nothing in these Terms and Conditions gives you any rights in respect of any intellectual property owned by Samsung, IB, MCB, their licensors or third parties and you acknowledge that you do not acquire any ownership rights by adding your Card to or using your Card in connection with Samsung Pay.

DISCLAIMERS OF WARRANTY

Samsung Pay is provided by Samsung without any warranty from IB or MCB. You acknowledge and agree that from time to time, your use of your Card in connection with Samsung Pay may be delayed, interrupted or disrupted for an unknown period of time for reasons we cannot control. Neither IB, MCB, nor their affiliates, agents, directors or officers will be liable for any claim arising from or related to use of your Card through Samsung Pay due to such delay, interruption, disruption or similar failure.

You acknowledge that we are not party to the terms and conditions for Samsung Pay between you and Samsung and we do not own and are not responsible for Samsung Pay. We are not providing any warranty for Samsung Pay. We are not responsible for maintenance or other support services for Samsung Pay and shall not be responsible for any other claims, losses, liabilities, damages, costs or expenses with respect to Samsung Pay, including, without limitation, any third-party product liability claims, claims that Samsung Pay fails to conform to any applicable legal or regulatory requirement, claims arising under consumer protection or similar legislation, and claims with respect to intellectual property infringement. Any inquiries or complaints relating to the use of Samsung Pay, including those pertaining to Intellectual Property Rights, must be directed to Samsung.

We do not recommend, endorse or make any representation or warranty of any kind regarding the performance or operation of your Eligible Device. You are responsible for the selection of an Eligible Device and for all issues relating to the operation, performance and costs associated with such Eligible Device.

LIMITATION OF LIABILITY

TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, IN NO EVENT SHALL WE, OUR PROGRAM MANAGER, PROCESSORS, SUPPLIERS, OR LICENSORS (OR THEIR RESPECTIVE AFFILIATES, AGENTS, DIRECTORS, AND EMPLOYEES) BE LIABLE FOR ANY DIRECT, INDIRECT, PUNITIVE, INCIDENTAL, SPECIAL, CONSEQUENTIAL, OR EXEMPLARY DAMAGES, INCLUDING WITHOUT LIMITATION DAMAGES FOR LOSS OF PROFITS, GOODWILL, USE, DATA OR OTHER INTANGIBLE LOSSES, THAT RESULT FROM THE USE OF, INABILITY TO USE, OR UNAVAILABILITY OF SAMSUNG PAY, INCLUDING YOUR USE OF YOUR CARD IN CONNECTION WITH SAMSUNG PAY. UNDER NO CIRCUMSTANCES WILL WE BE RESPONSIBLE FOR ANY DAMAGE, LOSS OR INJURY RESULTING FROM HACKING, TAMPERING OR OTHER UNAUTHORIZED ACCESS OR USE OF YOUR CARD IN SAMSUNG PAY.

TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, WE, OUR PROGRAM MANAGER, PROCESSORS, SUPPLIERS AND LICENSORS (AND THEIR RESPECTIVE AFFILIATES, AGENTS, DIRECTORS, AND EMPLOYEES) ASSUME NO LIABILITY OR RESPONSIBILITY FOR ANY (I) ERRORS, MISTAKES, OR INACCURACIES OF CONTENT; (II) PERSONAL INJURY OR PROPERTY DAMAGE, OF ANY NATURE WHATSOEVER, RESULTING FROM YOUR ACCESS TO OR USE OF SAMSUNG PAY, INCLUDING YOUR USE OF YOUR CARD IN CONNECTION WITH SAMSUNG PAY; (III) ANY UNAUTHORIZED ACCESS TO OR USE OF OUR SECURE SERVERS AND/OR ANY AND ALL PERSONAL INFORMATION STORED THEREIN; (IV) ANY INTERRUPTION OR CESSATION OF TRANSMISSION TO OR FROM SAMSUNG PAY; (V) ANY BUGS, VIRUSES, TROJAN HORSES, OR THE LIKE THAT MAY BE TRANSMITTED TO OR THROUGH SAMSUNG PAY BY ANY THIRD PARTY; (VI) ANY ERRORS OR OMISSIONS IN ANY CONTENT OR FOR ANY LOSS OR DAMAGE INCURRED AS A RESULT OF THE USE OF ANY CONTENT POSTED, EMAILED, TRANSMITTED, OR OTHERWISE MADE AVAILABLE THROUGH SAMSUNG PAY; AND/OR (VII) USER CONTENT OR THE DEFAMATORY, OFFENSIVE, OR ILLEGAL CONDUCT OF ANY THIRD PARTY. IN NO EVENT SHALL WE, OUR PROGRAM MANAGER, PROCESSORS, AGENTS, SUPPLIERS, OR LICENSORS (OR THEIR RESPECTIVE AFFILIATES, AGENTS, DIRECTORS, AND EMPLOYEES) BE LIABLE TO YOU FOR ANY CLAIMS, PROCEEDINGS, LIABILITIES, OBLIGATIONS, DAMAGES, LOSSES OR COSTS IN AN AMOUNT EXCEEDING $500.

THIS LIMITATION OF LIABILITY SECTION APPLIES WHETHER THE ALLEGED LIABILITY IS BASED ON CONTRACT, TORT, NEGLIGENCE, STRICT LIABILITY, OR ANY OTHER BASIS, EVEN IF WE HAVE BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGE. THE FOREGOING LIMITATION OF LIABILITY SHALL APPLY TO THE FULLEST EXTENT PERMITTED BY LAW IN THE APPLICABLE JURISDICTION.

INDEMNITY

You agree to indemnify, defend, and hold us and the Program Manager harmless (and the employees, directors, agents, affiliates and representatives of each) from and against any and all claims, costs, losses, damages, judgments, tax assessments, penalties, interest, and expenses (including reasonable attorneys' fees) arising out of any claim, action, audit, investigation, inquiry, or other proceeding instituted by a person or entity that arises out of or relates to: (a) any actual or alleged breach of your representations, warranties, or obligations set forth in this Terms and Conditions, including any violation of our policies; (b) your wrongful or improper use of Samsung Pay, including willful misconduct or fraud; (c) your violation of any third–party right, including without limitation any right of privacy, publicity rights or Intellectual Property Rights; (d) your violation of any law, rule or regulation of the United States or any other country; (e) any other party's access or use of Samsung Pay with your fingerprint identity or other appropriate security code.

REPRESENTATION AND WARRANTY

You represent and warrant to us that: (i) to the extent you identified a name at registration, the name identified by you when you registered your Card to be added to Samsung Pay is your name; (ii) the Card you added to Samsung Pay is your Card; (iii) you have the authority to authorize the receipt of notices, emails, calls and text messages from MCB or Program Manager at the phone number or email address you provide; (iv) you and all transactions initiated by you will comply with all federal, state, and local laws, rules, and regulations applicable to you, including any applicable tax laws and regulations; (v) you will not use your Card through Samsung Pay for any fraudulent or illegal undertaking or in any manner so as to interfere with the operation of Samsung Pay; and (vi) your use of your Card in connection with Samsung Pay will comply with these Terms and Conditions.

GOVERNING LAW

These Terms and Conditions, your use of your Card through Samsung Pay, and any claim, dispute or controversy arising from or relating to these Terms and Conditions shall be governed by the law of the State of New York, without giving effect to the conflict of law principles thereof, except to the extent preempted or governed by federal law. The legality, enforceability and interpretation of these Terms and Conditions and the amounts contracted for, charged and received under these Terms and Conditions, if any, will be governed by such laws. These Terms and Conditions are entered into between you and us in New York. Subject to the arbitration provision in the Cardholder Agreement, you expressly agree that exclusive jurisdiction for any claim or dispute with us or relating in any way to these Terms and Conditions or your use of your Card resides in the state and federal courts located in New York County, New York and you further agree and expressly consent to the exercise of personal jurisdiction in such courts in connection with any such dispute including any claim involving us or our affiliates, subsidiaries, employees, contractors, officers, directors, agents and content providers.

RISK DISCLOSURE REGARDING COMPLEX OR LEVERAGED EXCHANGE-TRADED PRODUCTS

Interactive Brokers ("IBKR") is furnishing this disclosure to clients to provide additional information regarding the characteristics and risks associated with Complex or Leveraged exchange-traded products ("ETPs"). Complex or Leveraged Exchange-Traded Products ("ETPs") are funds or notes that trade on an exchange but have very different characteristics from shares of stock or ordinary exchange-traded funds (ETFs) such as an S&P 500 Index ETF. Complex or Leveraged ETPs may include, but are not limited to: (1) leveraged ETFs and ETPs; (2) inverse ETFs and ETPs; (3) volatility-linked ETFs and ETPs; (4) Exchange-Traded Notes ("ETNs"); (5) cryptocurrency ETFs and ETPs; and (6) any other ETP that uses derivatives, that contains imbedded leverage, or that is based on an exotic or volatile underlying commodity or index or financial product.

In addition to providing this disclosure, IBKR strongly encourages clients to carefully review the prospectus, Key Information Document or other available disclosures relating to the specific ETF, ETN or other ETP before investing, to understand its unique features, risks, fees, tax treatment and other characteristics.

LEVERAGED FUNDS

As the name implies, leveraged mutual funds and ETFs seek to provide leveraged returns at multiples of the underlying benchmark or index they track. Leveraged funds generally seek to provide a multiple (i.e., 200%, 300%) of the daily return of an index or other benchmark for a single day excluding fees and other expenses. In addition to using leverage, these funds often use derivative products such as swaps, options, and futures contracts to accomplish their objectives. The use of leverage as well as derivative instruments can cause leveraged funds to be more volatile and subject to extreme price movements, potentially causing rapid losses.

INVERSE FUNDS

Inverse mutual funds and ETFs, which are sometimes referred to as "short" funds, generally seek to provide the opposite of the single day performance of the index or benchmark they track. Inverse funds are often marketed as a way to profit from, or hedge exposure to, downward moving markets. Some inverse funds also use leverage, such that they seek to achieve a return that is a multiple of the opposite performance of the underlying index or benchmark (i.e., -200%, -300%). In addition to leverage, these funds may also use derivative instruments to accomplish their objectives. As such, inverse funds are volatile and entail the potential for significant losses.

VOLATILITY-LINKED PRODUCTS

Volatility-linked ETPs are generally designed to track a volatility measure, typically the Chicago Board Options Exchange Volatility Index (VIX) futures. The VIX is a measure of the expected volatility of the S&P 500 index as measured by the implied volatility of options on that index. Volatility ETPs gain exposure to market volatility through futures and/or options contracts on the VIX. Volatility-linked ETPs that seek to maintain a continuous, targeted maturity exposure to VIX futures will either track or hold VIX futures contracts on a rolling basis. They will sell shorter-term contracts or contracts about to expire and replace them with contracts that have more distant or deferred maturity dates in order to maintain the desired exposure. The performance of volatility-linked ETPs may be significantly different than the performance of the VIX and the actual realized volatility of the S&P 500 Index. VIX futures contracts are among the most volatile segments of all futures markets. Volatility-linked ETPs may be subject to extreme volatility and much greater risk of loss than other traditional ETFs.

EXCHANGE-TRADED NOTES

ETNs are a type of debt security that trade on exchanges and promise a return linked to a market index or other benchmark. ETNs are unsecured debt obligations of the issuer-typically a bank or another financial institution. Unlike traditional bonds, ETNs typically do not pay any interest payments to investors. Instead, the issuer promises to pay the holder of the ETN an amount determined by the performance of the underlying index or benchmark on the ETN's maturity date (typically 10, 30 or in some cases even 40 years from issuance), minus any specified fees. In addition, unlike traditional bonds, ETNs trade on exchanges throughout the day at prices determined by the market, similar to stocks or ETFs. But unlike ETFs, ETNs do not buy or hold assets to replicate or approximate the performance of the underlying index.

Some ETNs provide exposure to familiar, broad-based indexes, while others do so to less familiar asset classes or newer, more complex, or even proprietary indexes. For example, there are ETNs linked to indexes that track emerging markets, commodities such as gold and oil, foreign currencies and market volatility. Some of the indexes and investment strategies used by ETNs can be quite sophisticated and may not have much performance history. The return on an ETN generally depends on price changes if the ETN is sold prior to maturity (as with stocks or ETFs)-or on the payment, if any, if the ETN is held to maturity or redeemed (as with some other structured products).

Some ETNs offer leveraged exposure to the index or benchmark they track. This means that they promise to pay a multiple of the performance of the underlying index or benchmark. For example, an ETN that offers two times-or "2x"-leverage promises to pay twice the performance of the index it tracks.

Inverse ETNs offer to pay the opposite of the performance of the index or benchmark they track, and leveraged inverse ETNs seek to pay a multiple of the opposite of the performance of the index or benchmark they track. Some leveraged, inverse or leveraged inverse ETNs are designed to achieve their stated performance objectives on a daily basis and "reset" their leverage or inverse exposure on a daily basis. Given the daily resetting of its leverage factor, an ETN that is set up to deliver twice the performance of a benchmark on a daily basis will not necessarily deliver twice the performance of that benchmark over longer periods such as weeks, months or years. Due to the effect of compounding, their performance over longer periods of time can differ significantly from the stated multiple of the performance (or inverse of the performance) of their underlying index or benchmark during the same period of time.

Generally, leveraged and inverse ETNs are designed to be short-term trading tools and are not intended for buy-and-hold investing. Other leveraged, inverse or leveraged inverse ETNs can have monthly resets or even no resets, so it is important to distinguish one type from another and understand how their performance may differ.

ETNs list on an exchange and can be bought and sold at market prices, similar to other exchange-traded investments. Market prices of ETNs may fluctuate due to movements in the indexes they track, as well as other factors, including ETN issuances and redemption activity. Issuers of ETNs issue and redeem notes as a means to keep the ETN's price in line with a calculated value, called the indicative value or closing indicative value for ETNs. This value is calculated and published at the end of each day by the ETN issuer. When an ETN is trading at a premium above the indicative value, issuing more notes to the market can bring the price down. Similarly, if an ETN is trading at a discount, redemption of notes by the issuer reduces the number of notes available in the market, which tends to raise the price.

ETN issuers have primary control over the issuance and redemption processes in the ETN market. The decision to issue additional notes is at the issuer's sole discretion. Investors may initiate the redemption process prior to an ETN's maturity date, following precise steps laid out by the issuer in the prospectus. The process generally begins by submitting a "notice of redemption" form to the issuer. Given the various steps in the process, transaction fees-and especially the large number of ETNs required to initiate a redemption (usually 25,000 or 50,000)-redemption is not generally a practical source of liquidity for most retail investors. If a redemption occurs, the issuer will redeem the notes at the ETN's indicative value.

Indicative values are generally based on the value of the underlying index or benchmark, minus certain fees (sometimes referred to as "daily investor fees"), which vary across ETNs and can fluctuate for a given ETN. ETNs also typically have an intraday indicative value that is calculated and published every 15 seconds during the trading day under the applicable trading symbol by the market in which the ETN trades. Each ETN uses its own formula for computing its indicative value, which is generally outlined in the ETN's prospectus or pricing supplement.

An ETN's closing indicative value, as well as its intraday indicative value, are distinct from an ETN's market price, which is the price at which an ETN trades in the secondary market. In theory, an ETN's market price should closely track its closing and intraday indicative values. However, an ETN's market price can deviate, sometimes significantly, from its indicative value. Price deviations can happen for a variety of reasons. For example, an ETN might trade at a premium to its indicative value if the issuer suspends issuance of new notes. Paying a premium relative to the indicative value to purchase the ETN in the secondary market-and then selling the ETN when the market price no longer reflects the premium-can lead to significant losses for an investor. This occurred when an ETN experienced price movement that diverged significantly from its indicative value and the performance of the index it tracks, due in part to suspensions in the issuance of new notes, which caused the ETN to trade at a significant premium-nearly 90 percent. When the issuer of the ETN resumed the issuance of new notes, the market price of the ETN fell sharply-dropping by more than half in two days. For this reason, before trading in the secondary market, it's a good idea to compare an ETN's closing and intraday indicative values with the market price. If the ETN is trading at a significant premium to its closing or intraday indicative value, you might want to consider similar products that are not trading at a premium, or that provide similar exposure to the index or asset class. It's also a good idea to ask whether the issuer has suspended issuing new notes, and if so, why.

CRYPTOCURRENCY-LINKED ETPs

Cryptocurrency linked ETPs are designed to provide exposure to one or more cryptocurrencies. These products may invest directly in cryptocurrencies by buying and selling them in the cash market, or they may invest in cryptocurrency futures contracts (or options on such futures contracts) by trading them on futures exchanges.

ETPs that trade cryptocurrencies on cash markets expose investors to risks associated with those markets, which may include:

• extreme price volatility;
• risk that these cash markets or specific cryptocurrencies may become illiquid;
• lack of regulation or supervision by a government agency;
• risk of manipulation; and
• a lack of critical system safeguards, which may give rise to risks associated with hacking or "flash crashes".

Cryptocurrency futures contracts are bought and sold using leverage. If the price of the futures contract moves in an unfavorable direction, the leveraged nature of the investment can produce large losses. Cryptocurrency futures contract prices are impacted by many of the same risks that are associated with prices in the cash markets. The use of leverage amplifies the impact of the occurrence of an adverse event in the cash markets and means that the same event may produce greater losses in an ETP that invested in cryptocurrency futures than an ETP that invested directly in the underlying cryptocurrency. But ETPs that invest in futures may not be subject to the same risks of loss related to hacking, or theft or loss of the cash cryptocurrency.

These characteristics, as well as the novelty of cryptocurrencies and cryptocurrency ETPs, subject investors in these products to a far greater risk of loss than is associated with ETPs that invest in traditional securities or commodities.

RISKS ASSOCIATED WITH COMPLEX OR LEVERAGED ETPS

Complex or Leveraged ETPs are complicated instruments that should only be used by sophisticated investors who fully understand the terms, investment strategy and risks associated with the funds. In particular, clients should be aware of certain specific risks involved. These risks include, but are not limited to:

Use of Leverage and/or Derivative Instruments: Many leveraged and inverse funds as well as volatility-linked products use leverage and derivative instruments, such as futures and options contracts, to achieve their stated investment objectives. As such, they can be extremely volatile and carry a high risk of substantial losses. Complex or Leveraged ETPs are considered speculative investments and should only be used by investors who fully understand the risks and are willing and able to absorb potentially significant losses.

Seek Daily Target Returns: Many Complex or Leveraged ETPs "reset" daily, meaning that they are designed to achieve their stated objectives on a daily basis. Due to the effect of compounding, the return for investors who invest for a period longer than one trading day may vary significantly from the stated goal as well as the target benchmark's performance. This is especially true in very volatile markets or if an ETP is tracking a very volatile underlying index. Investments in any ETP must be actively monitored on a daily basis and are typically not appropriate for a buy-and-hold strategy.

Higher Operating Expenses and Fees: Investors should be aware that these ETPs typically rebalance their portfolios on a frequent basis, often daily, in order to compensate for anticipated changes in overall market conditions. For example, volatility-linked ETPs will rebalance their exposure to futures of different maturities to maintain the targeted maturity. This rebalancing can result in frequent trading and increased portfolio turnover. These ETPs will therefore generally have higher operating expenses and investment management fees than other funds or products.

Tax Treatment May Vary: In many cases, Complex or Leveraged ETPs may generate their returns through the use of derivative instruments. Because derivatives are taxed differently from equity or fixed-income securities, investors should be aware that these ETPs may not have the same tax efficiencies as other funds or products.

Credit Risk: ETNs are unsecured debt obligations of the issuer. If the issuer defaults on the note, investors may lose some or all of their investment.

Market Risk: ETPs are market-linked: the value of an ETP is largely influenced by the value of the index it tracks or underlying investments it is based on. Make sure you understand what underlying or index is being tracked by the ETP-for example, some indices reflect a dynamic trading strategy and others are based on futures markets. Also, some indices reflect "total returns" while others may not.

Liquidity Risk. Although ETPs are exchange-traded, they do carry some liquidity risk. As with other exchange-traded products, a trading market may not develop. In addition, under some circumstances, issuers can delist an ETP. If this happens, the market for the ETP can dry up or evaporate entirely.

• Price-Tracking Risk. ETPs typically trade at prices that closely track their indicative values, but this might not always be the case. When trading in the secondary market, check market prices against indicative values, and be wary of buying at a price that varies significantly from closing and intraday indicative values.
• Holding-Period Risk. Some ETPs, particularly some leveraged, inverse and inverse leveraged ETNs, are designed to be short-term trading tools (with holding periods as short as one day) rather than buy-and-hold investments. Because of the effects of compounding, the performance of these products over long periods can differ significantly from the stated multiple of the performance (or inverse of the performance) of the underlying index or benchmark during the same period.
• Call, Early Redemption and Acceleration Risk. Some ETNs are callable at the issuer's discretion. In some instances ETNs can be subject to early redemption or an "accelerated" maturity date at the discretion of the issuer or one of its affiliates. Since ETNs may be called at any time, their value when called may be less than the market price that you paid or even zero, resulting in a partial or total loss of your investment.
• Conflicts of Interest. There are a number of potential conflicts of interest between you and the issuer of these products. For example, the issuer of ETNs may engage in trading activities that are at odds with investors who hold the notes (shorting strategies, for instance). Search the ETN's prospectus for any mention of "conflicts of interest" and evaluate whether these conflicts are worth the risk.

BEFORE YOU INVEST

Make sure you have answers to the following questions so that you can better assess whether an ETP investment is right for you:

• Who is the issuer? Once you know, be sure to research the issuer's credit rating and financial situation. If the issuer is publicly traded, use the SEC's EDGAR database. Keep in mind that for ETNs, they are not registered investment companies and therefore are not subject to the same registration, disclosure and other regulatory requirements as most ETFs or mutual funds.
• What index or benchmark does the ETP track? If it involves an unfamiliar market or asset class, ask yourself whether you feel informed enough about the market or asset to effectively assess the risks involved.
• Is the ETP callable by the issuer? You can find this out by reading the prospectus or asking your financial professional.
• Does the ETP offer leveraged or inverse exposure to the underlying index or benchmark? If so, how frequently does it "reset"? One clue may be in the ETP's name: words like "daily" and "short-term" often indicate that the product resets daily and is not intended to be held for long periods of time.
• What fees and costs are associated with the ETP? ETPs differ widely with respect to fees, including the investor fee charged in connection with redemptions. Read the prospectus and ask your investment professional to clearly explain any fees and expenses associated with a given ETN.
• What are the tax consequences? The tax treatment of ETPs can vary depending on the nature of the ETN. Check with your tax advisor if you are unsure about the tax implications of a particular investment.
  

Interactive Brokers Negative Contract Prices Risk Disclosure

Interactive Brokers ("IBKR") wishes to remind you of the risks associated with trading in the futures markets if the market moves against your futures positions. These risks may be particularly acute in those instances in which a futures contract settles at a negative price. The circumstances that lead a futures contract to settle at a negative price may vary. For example, a futures contract with a physical commodity as the underlying asset may settle at a negative price when the supply of the commodity faces physical constraints in distribution or storage to such an extent that some suppliers are prepared to pay others to physically take away the commodity. Futures contracts across other asset classes also may settle at negative prices for a number of reasons. Regardless of whether prices are positive or negative, you should keep in mind that if the market moves against your futures positions:

• You may sustain a total loss of the funds that you have deposited to establish or maintain your positions and may incur additional losses beyond these amounts;
• You may be called upon to deposit additional margin funds, on short notice;
• If you do not provide the additional funds within the time we require, your positions may be liquidated at a loss; and
• You will be liable for any resulting deficit in your account.

Risk Disclosure for Trading Digital Assets with Paxos Trust Company Through IBKR's Platform

Important Information Regarding Trading Digital Assets with Paxos

Interactive Brokers LLC ("IBKR") offers clients the ability to access digital asset trading and custody services (the "Paxos Services") in an account in client's name (the "Paxos Account") at Paxos Trust Company ("Paxos") through IBKR's electronic trading software. The digital assets in your Paxos Account are carried at Paxos while all other assets are carried in your IBKR account. Fiat currency is carried in your IBKR account and may also be carried in your Paxos Account if you designated that account as your source of payment for digital asset purchases pursuant to the Supplement to Interactive Brokers LLC Client Agreement in Connection with Trading Digital Assets with Paxos Trust Company Through IB’s Platform (“Payment Source Account”) and moved fiat currency into that account in anticipation of purchasing digital assets. You should carefully consider the risks below before making a decision to utilize the Paxos Services.

1. Trading Of Digital Assets is Risky. Digital asset prices are highly volatile and can rise or fall dramatically and quickly. If you hold a position in digital assets and the value of the asset falls, you can lose money. You should carefully consider your financial circumstances and your risk tolerance before trading digital assets with Paxos and you should not trade digital assets unless you have the financial capability to sustain losses if they occur. You should be aware that you may sustain a total loss of the assets in your Paxos Account.


2. No Investment Advice, Recommendations, Or Tax Advice. IBKR does not provide investment, tax, or trading advice or recommendations. By making digital assets available to you, neither IBKR nor Paxos makes any assessment, representation, or warranty concerning the appropriateness or suitability of digital assets for your financial circumstances. The Paxos Services are "execution only." IBKR and Paxos will not advise you on any transaction. Neither IBKR nor Paxos will assess whether your transactions are suitable for you or help you avoid losses. You should obtain your own financial, legal, taxation, and other professional advice as to whether digital assets are appropriate investments for you.


3. Digital Asset Holdings Are Not Covered By FDIC or SIPC. In general, US broker-dealers cannot custody non-securities digital assets. Therefore, US brokers seeking to offer their clients the ability to trade digital assets must work with another entity (a "Crypto Broker/Custodian") which is suitably licensed, and at which clients trading digital assets have separate accounts in their own name. These Crypto Broker/Custodians are not broker-dealers, and so SIPC coverage does not apply to accounts at Crypto Broker/Custodians. Likewise, most Crypto Broker/Custodians are not insured banks, and digital assets are not cash, so FDIC coverage does not apply to digital assets held in accounts at Crypto Broker/Custodians.
   
   IBKR has selected Paxos as the Crypto Broker/Custodian with which to work. By requesting trading permissions for digital assets through IBKR's platform, you are opening an account in your name at Paxos (the previously mentioned Paxos Account). All trading you do in digital assets through IBKR's platform will be executed in your Paxos Account (and not an account at IBKR), and Paxos will be your custodian and counterparty for those trades, which means that Paxos holds your digital assets for you and represents your ownership of them on their internal ledger. As explained above, the holdings in your Paxos Account are not protected by FDIC or SIPC insurance in the event of Paxos' or IBKR's insolvency.
   
   Notwithstanding the above, because IBKR is a member of the National Futures Association (the "NFA"), IBKR is required to provide you with the following disclosure in connection with trading digital assets / "virtual currencies":
   
   INTERACTIVE BROKERS LLC IS A MEMBER OF NFA AND IS SUBJECT TO NFA'S REGULATORY OVERSIGHT AND EXAMINATIONS. HOWEVER, YOU SHOULD BE AWARE THAT NFA DOES NOT HAVE REGULATORY OVERSIGHT AUTHORITY OVER UNDERLYING OR SPOT VIRTUAL CURRENCY PRODUCTS OR TRANSACTIONS OR VIRTUAL CURRENCY EXCHANGES, CUSTODIANS OR MARKETS.
   
   
4. Trading Hours May Be Limited; Paxos Web Interface; Stop Loss Orders. Digital assets generally trade 24/7, and their prices may change dramatically over the weekend. But your ability to access your Paxos Account through IBKR's platform, including purchasing or selling digital assets over the weekend, may be limited. Please visit IBKR's public website for additional detail on trading hour limitations.
   
   To mitigate this risk, Paxos will make available to you at https://ibkr.paxosclients.com/, on a best-efforts-basis, a separate web-based interface (the "Paxos Web Interface"). Through the Paxos Web Interface, you can view digital asset positions at any time, and you can place orders to close (or reduce) positions in digital assets at times when IBKR's platform is unavailable for trading. If you have designated your Paxos Account as your Payment Source Account, you may also place buy orders directly with Paxos through the Paxos Web App, subject to the requirement that buy orders must be fully funded (including commission) when placed.
   
   Paxos may offer stop and/or stop-limit orders (generally, "stop-loss orders") that you may choose to use to manage your risk, with respect to sudden decreases in the value of digital assets in your Paxos Account.
   
   A stop order is an order to buy or sell a digital asset once the price of the digital asset reaches a specified price (the "stop price"). When the stop price is reached, a stop order becomes a market order and can execute at any price (not necessarily at the stop price). A sell stop order is entered at a stop price below the current market price. Investors generally use a sell stop order to limit a loss or to protect a profit on a digital asset that they own.
   
   A stop-limit order is an order to buy or sell a stock that combines the features of a stop order and a limit order. Once the stop price is reached, a stop-limit order becomes a limit order that will be executed (if possible) at a specified price (or better). Like a regular limit order, stop-limit orders will only execute if there is liquidity at your limit price or a better price.
   
   In a quickly falling market, including in situations where many customers submit stop orders with a similar stop price, or when there is a lack of liquidity in the market, a stop order may execute a significant amount away from the specified stop price and a stop-limit order may not execute at all.
   
   Stop and stop-limit orders, while outstanding, are eligible to execute even outside of the times when IBKR's platform is available for trading.
   
   Using stop orders carries its own risks, including that your order may execute at an unfavorable price, and that the price of the digital asset may subsequently rise sharply above the level of the stop price, and you could lose money if you then reestablish your position at a price above the price at which you exited it as a result of your stop-loss order executing.
5. Digital Asset Purchases Must Be Fully Funded When Orders Are Submitted. You are responsible for ensuring that there is sufficient cash available in your designated Payment Source Account to fully fund your purchase of digital assets at the time you submit an order. If you have designated your Paxos Account as your Payment Source Account, you are responsible for transferring cash from IBKR to Paxos before placing a buy order. If you have designated your IBKR brokerage account as your Payment Source Account, IBKR will transfer cash from your IBKR brokerage account to Paxos when you execute a trade to purchase digital assets. Orders that are not fully funded will be rejected.


6. The Digital Asset Market Is Highly Speculative And Extremely Volatile. The market for digital assets can be extremely volatile. The price of digital assets may be influenced by, among other things, the performance of the economy as a whole; new or amended government regulation; the changing supply and demand relationships for digital assets; governmental, commercial and trade programs and policies; interest rates; technological developments; inflation; national and international political and economic events; statements by internet celebrities; social media sentiment; and the prevailing psychological characteristics of the relevant marketplace.


7. Digital Assets Custodied with Paxos Will Have No Margin Value In Your IBKR Account. The assets (whether digital or cash) custodied in your Paxos Account will not be assigned any margin value. Such digital assets will not be considered in determining your IBKR account's compliance with either securities or commodities margin requirements. If you have insufficient equity in your IBKR account to meet your margin requirements, the assets in your IBKR account may be liquidated.


8. Digital Assets Carry Liquidity Risk. Paxos is not obligated to provide quotes for digital assets at any time, and neither Paxos (nor IBKR) guarantee the continuous availability of quotations or trading for digital assets on Paxos' or any other digital asset exchanges. Paxos may in its sole discretion cease quoting digital assets and/or cease entering new digital asset transactions at any time.


9. You Will Pay Commissions For Trading Digital Assets. Paxos will charge commissions on your digital asset trades. For more details on the commissions, please see https://www.interactivebrokers.com/en/index.php?f=1590.


10. Your Agreement with Paxos Governs Your Paxos Account. Your Paxos Account is governed by the Paxos Exchange Terms & Conditions ("Paxos T&Cs"). You should read the Paxos T&Cs carefully and understand the terms of your relationship with Paxos.


11. You Are Not Permitted To Short Digital Assets. Short sales of digital assets are prohibited. The inability to open short digital asset positions may negatively impact your ability to protect against trading losses.


12. The Digital Assets Available to You Are Limited and Subject to Change. The digital assets available for trading in your Paxos Account are limited. Paxos or IBKR may further limit the available digital assets to be traded on the IBKR platform at their own discretion and without prior notice to you. A complete list of available digital assets that may be purchased in your Paxos Account through IBKR's platform is available at https://www.interactivebrokers.com/en/index.php?f=46390.


13. Risk Of Disruption Or Interruption Of Access To Paxos Account. Both IBKR and Paxos rely on computer software, hardware and telecommunications infrastructure and networking to provide their respective services to you, and without these systems neither can provide you with access to your respective accounts. These computer-based systems and services such as those used by Paxos are inherently vulnerable to disruption, delay or failure, which may cause you to lose access to the IBKR trading platform and thereby your Paxos account or may cause IBKR or Paxos not to be able to provide digital asset quotations or trading, or may negatively affect any or all aspects of Paxos' services. Under the IBKR Client Agreement, you accept the IBKR systems and services "As-ls" and IBKR's liability to you is limited.


14. Other Important Information Covered by Paxos Terms & Conditions. If at any time you wish to transfer some or all of your digital asset holdings in your IBKR-linked Paxos account out of your IBKR-linked Paxos account and into an independent Paxos account (from which you can then continue to freely trade such assets or transfer them to other addresses on the blockchain), please see the Paxos Terms & Conditions for instructions on how you may do so. In the event that IBKR ceases operations, Paxos will contact you to transfer the holdings in your IBKR-linked account to an independent account, in accordance with the Paxos Terms & Conditions.

PRC RESIDENT PIPL ACKNOWLEDGEMENT

I/We acknowledge that:

• Interactive Brokers and its affiliates ("IBKR") may obtain information (including personal information and sensitive personal information, each as defined in the Personal Information Protection Law of the People's Republic of China ("PIPL") about me/us or my/our directors, shareholders, employees, officers, agents or clients as necessary. IBKR shall comply with applicable data protection laws with regards to processing personal data. I/We acknowledge that I/we have read and understood the Interactive Brokers Group Privacy Policy published on www.interactivebrokers.com (as may be updated from time to time) which sets out how personal data shall be processed by IBKR.
  
  
• IBKR may use, store or otherwise process any such information (whether provided electronically or otherwise) and may disclose any such information (including, without limitation, information relating to my/our transactions and account) either as IBKR shall be obliged to under or pursuant to any applicable law or rules or by any regulatory authority or as may be required to provide services to me/us under the client agreement with IBKR ("Agreement").
  
  
• IBKR may:
  
  
  • disclose information about me/us to my/our agents or attorneys for any purpose relating to the Agreement;
    
    
  • disclose information about me/us and my/our clients, of a confidential nature, in the circumstances set out in this clause:
    
    
    • to other members of the Interactive Brokers Group, who may use it in the manner set out in this clause (and for the avoidance of doubt, references to "IBKR" in this clause shall be deemed to include all members of the Interactive Brokers Group);
      
      
    • to other organizations and individuals IBKR may engage to perform, or assist in the performance of, IBKR's services or to advise me/us, provided that they will only be given access to the relevant information for that purpose;
      
      
    • to any depository, stock exchange, clearing or settlement system, account controller or other participant in the relevant system, to counterparties, dealers, custodians, intermediaries and others where disclosure is reasonably intended for the purpose of effecting, managing or reporting transactions in connection with the Agreement or establishing a relationship with a view to such transactions;
      
      
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    • as may be required for the purposes set out in this clause.
      
      
  • To the extent such authorization is required by law, I/we hereby authorize IBKR, directly or through third parties, to make any enquiries that IBKR considers necessary to conduct business with me/us. This may include ordering a credit report and performing other credit checks, or verifying the information I/we provide against third party databases. Any personal data obtained is maintained in accordance with the Interactive Brokers Group Privacy Policy.
  
  

For more information on how IBKR may use, store, or otherwise process client information, please refer to the Interactive Brokers Group Privacy Policy for details and contact information.